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W. P. 0. HARDING. GOVERNOR PAUL M. WARBURG, Vice Governor FREDERIC A. DELANO ADOLPH C. HILLER C H A g gj^ ?. HAMLIN EX-OFFICIO MEMBERS WILLIAM 0. HcADOO SECRETARY O F THE TREASURY CHAIRM AN JOHN SKELTON WILLIAMS FEDERAL RESERVE B O A R D COMPTROLLER O F THE CURRENCY WASHINGTON H. PARKER WILLIS. SECRETARY SHERMAN P. ALLEN. ASST.SECRETARY and fiscal Agent ADDRESS REPLY TO FEDERAL RESERVE BOARD Dear Sir:The Federal Reserve Board has bad under consider ation the payment of dividends by Federal Reserve banks. In the future when it is the intention t d ’Sabmit to the Board of Directors of your bank the quest fin the payment of a divi dend, the Federal Reserve Board desires tj#vhave you furnish it, a sufficient length of time prfcbr submission, with the following information 1. Darnings. 3. Current expenses, including post of Federal reserve notes used; Depreciation in vault and equipment; Ket earnings; . Per cent and amount if dividend suggested; Balance the surplus and profit and loss accounts at the time of rendering statement, and estimated surplus after allowing for payment of dividend. 3. Unpaid indebtedness' of closed banks to Federal Reserve • bank: (a) How secured, . (b) Estimated losses. 4, Indebtedness1 to Federal Reserve bank of^ member banks considered to be in ever-extended or unsafe condition, giving names of banks, indebtedness o & each, and se curity, if any. . For your information it may be stated that the Boa^rd w • \ hflds that a Federal Reserve bank should, p r i w - t o the declara- •. p t i t o o f a dividend, make provision for the following:- « 500 ■2- d. Provide far its entire organization expense; 2. Provide for the cost of Federal Reserve notes used; 3* Provide for depreciation in furniture, vaults and ' equipment, and '.-'here real estate is owned, pro vide a substantial amount to reduce the book value; 4. Provide an amount equal to its estimated losses on obligations of closed institutions; 5. Frovide an amount equal to hotes or obligation's bear ing the endorsement of failed banks where such notes have been past' due fsr three months or more; 6. Set aside an amount equal to at least 10^«tf its not earnings during the first fer years to provide -fior unexpected expenses and losses. Attention >s directed' t4 tne f.-.ct dividends ..re cu.milative and constitute a first claift upon che earniags -of the banks. Deferred dividends should be p>.-id'when the earnings of the bank permit. It ia regarded as better policy to show a gradually increasing dividend than to establish a high rate -.vith the possibility that ic may be reduced. The policy of declaring full dividends to a specified date is more highly regarded than *r that of declaring dividends at a lower rate for a longer period. Very respectfully, Governor ♦ 840 * 502- FEDERAL RESERVE BOARD WASHINGTON:January 13, 1916* Hon. Paul M. Warburg, Foderal Reserve Board. Dear Mr. Warburg : A considerable volume of trade acceptances is coming forward from-the Orient to the N o t York market, d r a m by sellers of goods in the Orient upon m i l k n o m importing and manufactur ing concerns in the United States. These are purchased in the Orient by the branches pf the Hong Kong and Shanghai Banking Cor poration, the Yokohama Spocio Bank, the Chartered Bank of India, Australia and China, and othor similar banks and bankers. The branches of theso banks in N ott York City receive the bills from the Orient, have then acccptod and thon sell them in the opon market -frith their endorsement. Such bills sell at a rate equal to or approximating closely tho rate for bankers1 acceptances. Regulation T provides that ’’Before purchasing domestic bills of exchange, the Federal Reserve iBank must securo statements concerning the condition and standing of the draper of the paper, rin^ftif possible, also of the acceptor of the bill, sufficient to satisfy the bank as to the nature and quality of the paper to be purchased. ” In the case of bills of the kind I have described it •frould be manifestly impossible for us to securo statements of the draper and Governor Strong and I feci that it Tould be impracticable for the present, at least, to obtain statements from the acceptors, since they have no interest in That becomes of the bill. Yot it seems to us of importance that no should be able to buy such drafts Then endorsed by responsible banks or bankers ( from v/hom to could obtain satisfactory statements of conditions )• The establishmentof a steady market at Iot rates for such bills Till greatly facili tate the making of dollar exchange in the Orient, Till tend to croato competition for dollar bills among tho bill buyers there, and Till tend to an appreciation of the groat differentiation in favor of dollar exchange no.7 existing. Possibly in tho forthcoming regulation in cases .vhoro such bills are endorsed by banks or bankers and are sold on their credit, tho statement required might bo that of the bank or banker. Wo are anxious, horever, to make progress in the matter promptly and I pm Triting to inquiro Thothor it jould not bo possible for tho Board to adyise Federal Resorvo B ^ a k ^ p j s a temporary, modification, of Regular., tion T, that tho statcmohTT’rcquirod under paragraph V, in regard to ■ bills endorsed by banks or bankers, might be considered as applying to the banks or bankers, rather than to tho dravors and acceptors of bills. Requesting, that this may have the favorable attention of the Board. Respectfully yours, (Signed) PIERRE JAY CHARLES S. HAMLIN. GOVERNOR FREDERIC A. DELANO. VICE GOVERNOR PAUL M. WARBURG W. P. G . HARDING ADOLPH C. MILLER Ex-officio Members WILLIAM 6. MCADOO SECRETARY OF THE TREASURY CHAIRMAN JOHN SKELTON WILLIAMS FEDERAL RESERVE B O A R D Co m p tr o lle r o f th e C u r r en c y H. PARKER WILLIS. SECRETARY SHERMAN ALLEN. ASST. SECRETARY A DDRE88 REPLY TO WASHINGTON FEDERAL RESERVE BOARD 509January 22,1916. SIR: Enclosed please find 50 copies of revised forms Nos. 286b and 287b for reporting the monthly earnings and expenses of your bank. No change, has been made in the form of the report for the earnings except that the reading of the first two captions has been modified to agree with the reading of the corresponding items on Form 3^-* Under the second head should be included, therefore, the earnings from all open market purchases of trade acceptances, bankers* domestic acceptances and bankers* foreign trade accept ances. No provision has been made for reporting separately "Commissionspaid". Such commissions, in accordance with informal ruling of the Board under date of September 22, 1915* ( See page 3 O9 of the October Bulletin), should be treated as part of the purchase price or cost of the investment. Under the head of Current Expenses the following observa tions would seem pertinent : 1. Assessments on account of expenses of Federal Reserve Board should be apportioned to each month (regardless of the dates when paid) and cumulative figures of amounts charged since January 1 be shown in the second column. 2. The expenses of the several advisory bodies, in- , eluding the Federal Advisory Council, the Governors* and the Federal Reserve Agents’ conferences, should be segregated, these expenses to include fees, per diem allowances, travelling and other incidental expenses. 3* Items to be apportioned over a period should on day of payment, be charged to account "Expenses paid in advance" (BIDE- Form 3 ^)* pro rata amounts to be transferred to Current Expenses on the last day of each month and be included, under proper headings, on monthly report of expenses (Form 287b). if - 2- -509 Under the general head of Organization Expenses please report, in accordance with informal ruling of December 10, 1915> ( page 12 of the January BULLETIN), in short column the cost of Federal reserve notes is sued by the bank prior to January 1 not offset by cur rent earnings, and all other organization expenses shown on Form 3 ^ after closing of books for calendar year 1915* The total of these two items (HUNT) should equal the amount shown at the beginning of the year against item BEAM on Form jk* Attention is called to the provisions of the Board’s informal ruling of Decem ber 10, 1 9 1 5 ^ regarding the methods of amortizing the cost of Federal reserve notes and other organization expenses. 5* A separate account is set up for depreciation of furniture and equipment. This account is to show amounts written off in accordance with paragraph 5 of informal ruling of December 10, 1915• 6. The amount of item HALL shown at the foot of Form 227b should equal the amount shown against item BATH on Form 3 *+ as at close of business on the last day of each month. Items shown in memorandum on Form 2S6b represent amounts expended during the month on account of Federal reserve notes printed and shipped, including expressage, insurance, etc. ; also amounts paid during the month for furniture and equipment. As indicated in the heading, the figures in the second column against items HOLT and HERD in this memorandum should equal amounts shown against items BOOT and B0L0 on Form 3 ^+ as at close of business on the last day of the report month. Copies of the monthly report of earnings and expenses should be sent to us on or before the seventh of each month. Respectfully, Assistant Secretary. Enclosure b'aL'O 511 84tt Washington, D. C., January 24, 1916, ANALYSIS OF THE RESERVE CITY SITUATION, First; Under Clause (a) of Section 11, of the Federal Reserve Act, the Federal Reserve Board is authorized and empowered: "To add to the number of cities classified as reserve and central reserve cities under exist ing law in which national banking associations are subject to the reserve requirements set forth in Section twenty (should be 19) of this Act; or to reclassify existing reserve and central reserve cities or to terminate their designation as such," Second: The Reserve, requirements at the end of thirty-six months after the Banks were organized - i. e. until November 2, 1918, will be as follows: At the end of 36 months from the starting of the banks, (ice. November 2, 1918) the member banks will have the option of keeping the following percentages of their demand deposits in the manner indicated, depending upon their location: (a) Membe r Bank Located In (b) Required Minimum Federal Reserve Bank Vaults Required Minimum In own Vaults (e) (d) (c) i Reserve Which at Option of Member Bank may be Kept in Federal Reserve Total Total of Bank or in (b) and (c) Reserves Own Vaults Central) Reserve) Cities ) 6$ 7$ V 12$ 18$ Re se rve) Cities ) bfo 5% 4'jo 10$ 15$ 5$ * ”35 O j^ Q 8$ 12$ Country) Cities ) &Towns ) i 4$ i !' 511. Third: Under Section 19, of trhe Federal Reserve Act, which is tho Section making provision for the payment of reserves into the Federal Reserve Banks, the Banks in cities already known as central reserve cities or hereafter so defined, are required to pay in their reserve deposits at once, whereas, banks in reserve cities and non-reserve cities are given three years in which to transfer their reserves. Fourth; There are in the United States at the present time three central reserve cities and tn-fk-jCMn reserve cities. Grouping these cities according to the tweiW Federal Reserve Districts, the list appears as follows: List of Central Reserve and Reserve Cities, Grouped by Districts and According to Population* DISTRICT Ho. 9 : DISTRICT No. 1: (*) Boston Population 670,585 (*) Minneapolis St. Paul Population. 301,408 214,744 DISTRICT No. 2: (*) New York City Albany 4,766,883 100,253 DISTRICT No. 3: (* Philadelphia 1,549,008 DISTRICT No. 4: (* Cleveland Pittsburgh Cincinnati Columbus 560,663 533,905 364,463 181,548 DISTRICT No. 10. i Kansas City; Mo. Kansas City,Kans. Denver Omaha S.Omaha,Nebr. St.Joseph,Mo. Oklahoma City Wichita,Kans. Pueblo,Colo. Lincoln,Nebr, Topeka,Kans. Muskogee,Okla. 248,381 82,331 213,381 124,096 26,259 77,403 64,205 52,450 44,395 43,973 43,684 25,278 844 DISTRICT No.. 5: DISTRICT No. 11 : Baltimoro 558,485 Washington 331,069 !) Richmond 127,628 Charleston,S.C,. 58,883 DISTRICT No. 6: ‘ New Orleans (*)Atianta Birmingham Nashville Savannah Chattanooga San Antonio (*) Dallas Houston Ft. Worth, Galveston Waco 96,614 92,104 78,800 73,312 36,981 26,425 DISTRICT No, 12 : 339,075 154,389 132,685 110,364 65,064 44,604 (*) Sa n Fran cisco 416,912 319,198 Los Angeles 237,194 Seattle 207,214 Portland 104,402 Spokane Salt Lake City 92,777 82,972 Tacoma DISTRICT No. ,7: (*) Chicago 2,185,283 Detroit 465,766 373,857 Milwaukee Indianapolis 233,650 Bes Moines 86,368 Sioux City,la. 47,828 38,494 Dubuque Cedar Rapids 32,811 DISTRICT No. 8: (*) St. Louis Louisville 687,029 223,928 Federal Reserve Cities marked with (*) Fifth: In order to study the reserve situation from the standpoint given under.the law, a list of cities having a population of 100/300 or more, in. each District, is herein shown, also, a list of cities having 50,000, but less than 100,000. It will be noticed that there are fifty cities in the United States having a population of more than 100.000, and fifty-four cities having more than 50,000, but less than 100.000, For the convenience of the student of this question these cities are grouped by Federal Reserve Districts. (See Exhibit 'A ) EXHIBIT A 846 { LIST OF CITIES IN UNITED STATES HAVING A POPULATION OF OVER ONE HUNDRED THOUSAND Classified as to Federal Reserve Districts PJ-R.TR.XCT NO. 1 : (*) Boston, Hass. Providence,R *I . Worcester > Hass * New Haven^Conn, Fall River, Mass. Lowell, Mass. Cambridge, Mass, Bridgeport> Conn. DISTRICT NO- ? L 670,585 224 ,326 145,986 133,^05 119,295 105,294 104,839 102,054 (*) Chicago,111 Detroit,Mich. Milwaukee,Wis. ■ Indianapolis,Ind. Grand Rapids, Mich. DISTRICT NO. 8; (*) DISTRICT NO. 2: (*) New York City Buffalo, N.Y. Newark,N.J. Jersey City,N.J. Roche ster,N .Y. Syracuse ,N.Y., Paterson, N.J. Albany,N .Y . 4,766,883 423,715 347,469 267,779 218,149 137,249 125,600 100,253 (*) 687,029 223,928 131,105 Minneapolis,Minn, St,Paul,Minn. 301,408 214,744 DISTRICT NO. 10; (*) 1,549,008 129,687 St. Louis, M q » Louisville, K y . Memphis,Tenn. DISTRICT NO. 9: DISTRICT NO. 3: (*) . Philadelphia,Pa. Scranton,Pa. 2 ,185,283 465,776 373,857 233,650 112,571 Kansas City,Me. Denver, Colo. Omaha, Nebr. 248,381 213,381 124,096 DISTRICT NO. 11: DISTRICT NO. 4: DISTRICT NO. 12: (*) Cleveland,Ohio Pittsburgh,P a . Cincinnati,Ohio Columbus,Ohio Toledo,Ohio Dayton, Ohio 560,663 533,705 364,463 181,548 168,497 116,577 (*) San Francisco,Cal. Los Angeles, Cal. Seattle, Wash. Portland, Ore. Oakland, Cal. Spokane, Wash. 416,912 319,198 237,194 207,214 150,174 104,402 DISTRICT NO. 5: (*) Baltimore, M d . Washington, D.C. Richmond, Va. 558,485 331,069 127,628 This list totals 50 Cities. Note: -DISTRICT NO. 6: (*) New Orleans,La, Atlanta,Ga. Birmingham, Ala. Nashville, Tenn. 339,075 154,879 132,685 110,364 Federal Reserve Cities are marked with (*). (Exhibit A) (Sheet No,2 ) LIST OF CITIES IN UNITED STATES HAVING A POPULATION OF OVER FIFTY THOUSAND BUT LESS THAN ONE HUNDRED THOUSAND Classified as to iFederal Reserve Districts. DISTRICT NO. 1: Hartford, Conn, New Bedford, Mass, Lynn, Mass. Springfield, Mass. Lawrence, Mass. Manchester, N.H. Portland, Me. Holyoke, Mass, Brockton, Mass, Pawtucket, R.I, DISTRICT NO. 6: 98,915 96,652 89,336 88,926 85,892 70,063 58,571 57,730 56,878 51,622 Savannah,G a , Jacksonville, F1&Mobile > Ala, DISTRICT NO. 7: Des Moines, la, Peoria, 111. Ft, Wayne, Ind. Terre Haute, Ind. South Bend, Ind. Springfield, 111. Saginaw, Mich. DISTRICT NO. 2: Yonkers, N.Y. Troy, N.Y. Utica, N.Y. Elizabeth, N.J. Hoboken, N.J. Bayonne, N.J. Passiac, N.J. 79,803 76,813 74,419 73,409 70,324 55,545 54,773 65.C64 57,699 51,521 86,368 66,950 63,933 58,157 53,684 51,677 50,510 DISTRICT NO. 8: Evansville, Ind. 69,647 DISTRICT NO. 9: Duluth, Minn. 78,466 DISTRICT NO. 3: DISTRICT NO. 10: Trenton,N .J . Reading, Pa, Camden, N.J. Wilkes Barre,Pa, Harrisburg, Pa. Johnstown, Pa. Altoona, Pa. Allentoivn, Pa, 96,815 96,071 94,538 67,105 64,186 55,484 52,127 51,913 DISTRICT NO. 4: Youngstown, 0. Akron, 0. Erie, Pa. Covington, Ky. Canton, 0. 79,066 69,067 66,525 53,270 50,217 Kansas City, Kas. St. Joseph, He. Oklahoma City, Okla. Wichita, Kas. 62,331 77,403 64,205 52,450 DISTRICT NO. 11: San Antonio, Tex. (*) Dallas, Tex. • Houston, Tex. Ft, Worth, Tex. 96,514 92,104 78,810 73,312 DISTRICT NO. 12: Salt Lake City, Utah Tacoma, Wash. 92,777 83,743 DISTRICT HO. 5: Norfolk, Va. Charleston, S.C. 67,452 58,833 This list totals 54 Cities Note: F e d e r a l R e s e r v e C i t y marked ( * ) 84? 848 - -511- 6- The question naturally arises, whether this problem of greater reserves in certain banks than in others should be ap proached, (-) From the standpoint of the population of the city, on the theory that the banks in cities of considerable population are more vul nerable, e. g. liable to a run, than banks in country districts; (b) Based on the theory of the size of the bank, banks with large deposits being more vulnerable than banks of smaller deposits; or 5c) Based on the theory that different reserves should be kept against different classes of deposits. For instance, one basis of reserves against individual deposits, and a higher percentage against bank deposits. If we proceed on the population theory, we can go ahead under the Act as it is ; •; or we can even combine the population theory with that of geographical location, with that <;f distance and relations of the Federal Reserve Bank as a convenient agency. If, however, we proceed under proposals (b) or (c), we must ask for an amendment to the Federal Reserve Act. It may be said with a good deal of justice that it is unfair to apply a different rule of reserves to a small bank in the suburbs of a large city, which is, to all intents and purposes, a country bank , than applies to a country bank a few miles further away. However, this is an in justice which might be remedied by giving the large city baijks the right to operate branches in the same city. If some intelligent solution of this problem is not found, complaint will certainly be made by banks in central reserve cities that they are required to maintain reserves on a basis of say 18$ while given no privileges under the Act ( after the three year 511. - 7 - period) which do not apply to bank.' in smaller cities. The- result is certain to be that pressure will undoubtedly come to reduce reserve requirements down to the fifteen per cent or even to the twelve per cent level. Already banks in non reserve cities are asking to have their reserves reduced to nine per cent, Seventh: In order to show the effect on Federal Reserve Banks of giving Federal Reserve Cities the designation of Central Re serve Cities as provided in Section 11 of the Act, a table has been prepared showing the ratio to capital and'available re serve deposit.-. This table shows that in New York this ratio is .• 9 per cent whereas in the three Southern Districts, ex cluding special Government deposits of $ 5 ,0 0 0 , 0 0 0 each, it varies from 31,9 to 34,4 per cent, In order to show what the effect would be of requiring banks in these Federal Re serve Cities to carry IS per cent reserves instead of 15 per cent reserves, all of which should be paid in at once, an other table has been prepared to show the results of this designation. (See Exhibit B & C) In the case of the Minneapolis District, on account of the close proximity and great competition existing between St, Paul and Minneapolis banks, both of these cities have been treated as Central Reserve Cities. 850 EXHIBIT JO 511. • STATEMENT OF CAPITAL and RESERVE DEPOSITS -alsoPERCENTAGE OF COITAL TO THE CO IIPINED AMOUNTS OF CAPITAL AND 6 5 # OF RESERVE DFPOSITS (Figures ao of December 1,1913) (In thousands of dollars) Federal Reserve Bank of Paid-in C?.pital BOSTON 5,171 NET YORK 1 1 ,0 6 1 Roserve Deposits Percent Paid-in capital rPorcentage of capital plus 6 5 ^ of Re :to sum of Capital and Rcservo D o d o s its serve Donosits :65# of Rosorve Deposits 65 1 7 ,7 1 !* 2 2 ,8 8 5 22-2 1 7 1 ,11+1* 111,21*1* 1 2 2 ,3 0 5 9.0 27,252 PHILADELPHIA 5 ,2 7 c 23,72S 15,U23 2 0 ,6 9 3 25-5 CLEVELAND 5 ,9 3 1 2U,U36 15,883 2i; 811* 2 7 .2 RICHMOND 3,35** (a) 15, ll*9 (b) 10, ll*9 9 ,81*7 6,597 1 3 ,2 0 1 2 5 .1* 9,951 33*7 (a)12,100 2,1*21 ATLANTA 7 ,8 6 5 10,286 (b) 7,100 l*,6l5 7 ,0 3 6 23*5 3 I4A CHICAGO 6,6i+l 52,51*5 3 U,1 5 U 1*0 , 7 9 5 1 6 .3 ST.LOUIS 2,750 1 2 ,5 0 2 S,i26 1 0 ,9 0 6 2 5 .5 M inneapolis 2 /4 9 7 13,557 8,812 11,309 22*1 KANSAS CITY 3 ,0 3 0 13,692 8 ,9 0 0 11,930 2 5 .4 DALLAS 2 ,7 5 6 (a)ll* ,0 5 3 (b) 9,053 9,135 5,385 11,891 8,61*1 2 3 .2 17,331 1 1 ,2 6 5 1 5 ,2 0 7 25-9 3 1 3 ,2 2 2 17-5 13 a SAN FRANCISCO 3-,9*2 5U,85U TOTAL Nota: (a)397,!*89-258.363 (b)302,439 2 h o ,6 1 S 3 0 3 ,1*72 (-) I^c 1..o i v j of $j,jGC,CCO of Government Funds, (b) Exclusive of $5,000,000 of Government Funds t Division, Reverts & Statistics, 1/25/16. 31*9 EXHIBIT C. GJ 511 FEDERAL RESERVE DEPOSITS OF NATIONAL BANKS LOCATED IH THE NINE FEDERAL’RESERVE CITIES NAMED, AND ST. PAUL; ■ ALSO ADDITIONAL RESERVE DEPOSITS REQUIRED IN CASE THESE CITIES ARE MADE CENTRAL.RESERVE CITIES. (Figures in thousands of .dollars taken from-Comptroller's report for November 10, 1915) Net Amount on which ■reserve is coimuted. BOSTON * Reserve required after Nov. 16. 1915 Per ct. Amount Due from Federal 'Reserve Bank. Nov. 1C. 1915(a) Per ct. Amount 313,195 2.95 99,253 4 363,144 ' 3.50 12,713 CLEVELAND 88,778. 3.16 RICHMOND 31,34e ATLANTA ' Reserve required if the cities named were made Central •Reserve Cities Per ct. Amount Excess ovsr amount required after Nov. 16. 1915. Amount Per ct. Excess over amount held on Nov.. 10.1915(a) Per ct. Amount 12,528 7 21,924 4.05 12,671 .3 9,396 ■4 14,526 7 25,420 3.50 12,707 3 . 10,894 2,801 4 3,551 7 6,214 3.84 3,413 . 3 2, G53 . 3.23 1,027 4 1,274 7 2,229 . 3.77 . ^1,201. . ..'3 955 23,659 4,58 1,084 946 7 1,656 2.42 '572 .3 710 ST. PAUL ' MINNEAPOLIS 68,749. 82,175 2.52 2,66 1,733 .2,188 4 4 2,750 3,287 7 7 . 4,812 5,752 4.48 4.34 !3,079 3,564 3 3 2,062 2,4.65 KANSAS CITY. 84., 377 3.55 2,994 4 3,375 7 5,906 3.45 2,912 3 2,531 DALLAS . 24,152 3.34 806 4 966 7 1,691 3.66. 835- 3 725 142,084 2.69 3,827 4 5,683 7 9,946 .4.31 6,119 ■3 . 4,263 TOTAL • For nine F. R. Cities and St. 1,222,161 Paul. 3.14 38,426 4 48,886 7' 85,550 3.86 . 47,124 3 .36,664 PHILADELPHIA SAN FRANCISCO (a) ’1/25/16. . 4 . As shown by Comptroller's report.. 852 W. P. G. HARDING, GOVERNOR PAUL M. WARBURG, VICE GOVERNOR FREDERIC A. DELANO ADOLPH C. MILLER CHARLES S. HAMLIN Ex -Offic io Members WILLIAM G. McADOO SECRETARY OF THE TREASURY CHAIRMAN JOHN SKELTON WILLIAMS COMPTROLLER OF THE CURRENCY J FEDERAL RESERVE B O A R D H. PARKER WILLIS, SECRETARY SHERMAN P. ALLEN, ASST. SECRETARY WASHINGTON ADDRESS REPLY TO FEDERAL RESERVE BOARD A N l/ jli< a ?L < A G E N T January 2 5 l®l6 SIR: In a letter dated January 18, 1 9 1 6 , tronsr.itting a memorandum outlining a plan for handling unfit Federal reserve notes, the Board stated that the purpose of the plan was to afford Federal reserve hanks facilities for returning their own unfit Federal reserve notes nto the nearest suhtreasuries and through them to Washington.11 This statement was not intended to alter the procedure out lined, in the memorandum which that letter enclosed and which contem plates that shipments of unfit Federal reserve notes hy Federal re serve hanks shall he direct to the Treasurer at Washington. The Treas ury Department, however, has informed the Board that it m i l interpose no objection to the assistant treasurers extending to Federal reserve hanks the use of their mechanical facilities in cutting and preparing notes for shipment. Federal reserve hanks which are located in subtreasury cities may, therefore, arrange with assistant treasurers for permission to use the mechaiical equipment of the suhtreasuries for this purpose. It is suggested that lower halves he shipped first and uppers on a succeeding day, both shipments being given the same lot number in order that they may he easily identified. When both sets of halves have been received and verified...by the Treasurer in Washington he will notify both the Federal Reserve Agent and the Federal reserve hank, and the Federal Reserve Agent should immediately direct the Federal Reserve Board to transfer from his account with the Board to the account of the Federal reserve hank in the Geld Settlement Fund an amount equivalent to the value of the Federal reserve notes received hy the Treasurer for re demption; or, if a Federal Reserve Agent has no such account with the Federal Reserve Board, he should make the transfer direct to his hank in order that it may he reimbursed for the notes shipped for redemption. Because of the fact that the_ Federal. Reserve Board has no account with the Treasurer of the United States whereby book transfers could he made, this procedure will obviate the necessity of requiring innumerable transfers of actual funds from the Agent, or his account with the Board, to the Treasurer and a retransfer from the Treasurer to the Board for the account of the hank in the Gold Settlement Fund. Nothing herein contained,however,should be construed to do away v/ith the necessity of each Agent's keeping on deposit with the Treasurer five per cent of the amount of outstanding Federal reserve notes covered by a deposit with him of gold or lawful money. This amount will he held like the five per cent redemption fund of the Bank, primarily for the redemption of notes presented to the Treasurer hy holders other than the Federal reserve hanks. Enclosed are blanks of the forms referred to in paragraphs IV and V of .the procedure for disposing of unfit Federal reserve note Respectfully, Governor. FORM OF POTER OF ATTORNEY CONFERRING AUTHORITY INDICATED IN PARAGRAPH V OF THE PROCEDURE INVOLVING THE DISPOSITION OF UNFIT FEDERAL RESERVE NOTES, 516. KNOT ALL MEN BY THESE PRESENTS, That I,....................................... , .Federal Reserve Agent of the Federal Reserve Bank of ............ .......... .......... ...... , have constituted and ap pointed, and by these presents do constitute and appoint, the Treasurer of the United States my true and lawful At torney in fact, for me and in my name and stead, to trans fer and deliver to the Comptroller of the Currency for de destruction all unfit Federal reserve notes of the Federal Reserve Bank of ............................ , which the said Treasurer of the United States now holds, or may hold in tho future, for my account or subject to my order, and generally to do and perform any and every lawful act and thing necessary to effect such transfer and delivery. Witness my hand and seal this.................. day of .................... , A. D. 1916. Signed, sealed and delivered in presence of - (SEAL) ) ) ) w . P. G. H A R & & S G o ve r n o r PAUL M. WARBURG, VICE GOVERNOR KX>OPPICIO M EM BERS FREDERIC A. DELANO ADOLPH C. MILLER CHARLES S. HAMLIN WILLIAM 0. McADOO SECRETARY OF THE TREASURY CHAIRMAN JOHN SKELTON WILLIAMS Co m p t r o lle r o f tme Cu r r e n c y H. PARKER WILLIS. SECRETARY SHERMAN P. ALLEN, ASST. SECRETARY FEDERAL RESERVE B O A R D and F is c a l a g e n t ADDRES8 RE PLY TO W A S H IN G T O N FEDERAL RESERVE BOARD January 25, 1916. Sir: One of the Federal Reserve Agents has called atten tion to, and sent in for inspection, a number of Federal Re serve notes which have been seriously mutilated and marked up with blue pencil, or other disfiguring marks. While there is no law specifically covering this matter, it is generally under stood that the mutilating, disfiguring or counterfeiting of Fed eral Reserve notes, because Federal Reserve notes are obligations of the Government, must be regarded just the same as the mutilating, disfiguring or counterfeiting of other United States Government obligations; "greenbacks" for example, Tho practice of blue penciling notes in counting them or at other times, is very specifically forbidden in the case of Na tional bank notes, and it is perhaps a fair inference that it should not be permitted in the case of Federal Reserve notes, be cause the loss through the mutilation or disfigurment of Federal Reserve notes falls upon Federal Reserve banks and ultimately upon the National banks. It seems proper therefore, to call the attention cf the Federal Reserve Banks to the matter and suggest that they take it up with their member banks. Yours very truly, ' Governor, FORM OF RESOLUTION CONFERRING AUTHORITY INDICATED IN PARAGRAPH IV OF THE PROCEDURE INVOLVING THE DISPOSITION OF UNFI W l Tvrvr^ a r TVr?er,T^rF 'KTnTTi'S At a meeting qi the Board of Directors of the Federal Reserve Bank of . _______ 3 called pursuant to the provisions of the by-laws of said bank and held on the ____ day of > . 191^> the following Resolution was offered* seconded and duly adopted: !,BE IT RESOLVED* That the Treasurer of the United States be and he hereby is authorised^ empowered and directed to transfer to the account and hold subject to the order of ^ _______ ~j Federal Reserve Agent of the Federal Reserve Bank of _________ _______ i all unfit Federa.1 reserve notes of this bank which the said Treasurer of the United States now holds or may hold in the future for the account of this bank or subject to its order and to do c:lld perform any and every lawful act and thing necessary to effect such transfer-" I hereby certify that the foregoing is a true and correct copy of a resolution adopted and spread upon the minutes of the Board of Directors of this bank* held on the date specified* Cashier or Secretary Federal Reserve Bank of 1/25/16 857 521. An Analysis of the Condition of National and Other Member Banks of the Cleveland District ooo 0 ooo The Grouping of the Banks is as Follows; H CO OO ^ to «X> t>- 1. 2. 3. 4. S« 6. 7. Banks with Total Resources ox up to $100,000. it it 11 ii $200,000 " $100,000 to t> ii II IT 300,000 " 200,000 " u it 11 ii 500;000 " 300,000 " 1! n u IT 1,000,000 11 500,000 " II l! (i IT 10,000,000 " 1,000,000 " II II t! it ”10,000,000 and Ove r * 2/2/16 S2l 858 Data, taken from Reports of Condition cf Member Banks District No. 4 - Nov. 10, 1915. . Average Loans and Discounts per bank Croup 1. 33,307.54 Group 4. Croup 0. Group 3. 83,195.5£ 135,198,46 321,407.29 7.40 4.75 6,12 5.30 Officers and Directors Liability. Direct Indirect ■ 12.33 20.81 7.40 7.11 Pei4 cent of Eligible Paper 28.90 25.80 20.14 16.17 .95 1.75 1.50 1.75 Losses to Borrowers other than Banks 1913 - 1913 - 1914. Average Total Deposits per Bank 30,542,04 96,501.45 ' . 173,540.12 872,478.13 Per cent of Denying De posits to Total Deposits 89.93 80.05 70.77 67.55 Per-cent of Time De posits to Total Deposits 1C.07 19.95 29.23 32.45 Average Capital, Surplus and Undivided Profits per Bank 31,127.57 Per cent of Demand De posits Per cent of Time Deposit? Average Total Resources per Bank Per cent of Loans and discounts Per cent of Bonds, Se curities, etc. Per cent of Eligible Paper 34,357.37 48,811.13 75,468.05 88.34 335.81 251.65 243.89 9.63 56.25 1C3.9C 117.16 80,303.94 . 153,943.53 239,637.63 390,03.0.36 41.35 53.39 56.41 56.74 3.44 11.73 14.67 1&;27 11.95 14.31 11.36 9.15 859 521 » 3 — Data, taken from Reports of Condition of Member Banks District No. 4 - Nov. 10, 1915. (Continued) Group 5. Average Loans and Discounts per b3nk Officers and Directors Liability ' Direct Indirect Per cent of Eligible Paper Losses to Borrov/ors otnor than Banks 1912 - 1913 - 1914 Average Total Deposits per Bank 553,9 5C.58 Group 6. 2,956,792.50 Group 7 16,579,547.64 5.26 3.84 5.66 3.56 3.93 2.44 34.81 22.14 23.67 1.83 2.34 .91 680,721.64 4,009,916.89 27,738,738.85 Per cent of Descend De posits to Total Deposits 66.40 80.18 96.44 Per cent of Time De posits to Total Deposits 33.60 19.82 3.26 Average Capital, Surplus, ana Undivided Profits per Bank 194,200.39 1,052,744.37 5,741,892.93 Per cent of Derand De posits 232.76 296.95 465.89 Per cent of Time Deposits 117.76 73.39 17.19 Average Total Resources per Bank 976,841.33 5,583,969.11 35,317,345.37 Per cent of Loans and Discounts 56.71 52.95 46.25 Per cent of Bonds, Se curities, etc. 14.80 14.25 17.15 8.40 11.72 10.96 Per cent of Eligible Paper Comparative Market Values-of the Stock of the National Banks in Cleveland,Ohio. Bank. 1914 1913 Bank of Commerce, N. A. Central National Bank Cleveland National Bank First National Bank National Commercial Bank National City Bank Union National Bank 219 163 1 O65240 164 209 160 90 266 160 208i 160 220 165 030 10 3 I 6i —• 4 .. — —26 - - - - - -' ni 5 ooo COO ooo ooo ooc 000 Cap ital Nov.1914. 2, 0 00, 0 0 0 . Bank of Commerce N.A. 1 , 000 , 0 0 0 . Central National Bank Cleveland National Bank ■ 500,000. 3, 5 CC,000, First National Bank National Commercial Bank 1 , SCO,0 0 0 . 500,000. National City Bank l,6CG,O00. Union National Bank Average. . . . Decrease Increase 1,36S,536. 209 160 90 266 160 208| 160 179.08 Jan.1916. Increase • 19 190 185 105 300 160& 205 188 25 15 34 l 4 - 28 190.46 Bank of Commerce, N. .A. Central National Bank Cl&veland National Bank First National Bank National Commercial Bank National City Bank Union National Bank (* ) Depreciation. Net Increase. . . . . . 200 , 0 0 0 .* 30,000,* 82,500.* 650,000. 60,000.* 57,5C0.* 80,000.* 240,000. - - - - - - 3i —— 11.38 Net increase Stockholders * Advantage 1913 - 1914. Decrease 1914 - 1915. 380,000.* 250,000. 75,000. 850,000. 3,7500 17,500.* 448,000. 1,229,250. 861 _ 5- 521. Total percentage of Eligible Paper to Loans & Discounts . . ............... 19.97 Real Estate Loans to Loans & D i s c o u n t s ................. Officers & Directors Direct Liability to Loans ec Dis. , . Losses to borrowers, other than banks. 1912, 1913, 1914, to'Loans & Discounts.................. Average per year...................................... Time Deposits to Total Deposits ......................... 1.87 5.13 1.82 .507 19.25 Demand Deposits to Total D e p o s i t s ..........................00.75 Overdrafts to Total D e p o s i t s .................................. 04b Overdrafts to tbssfeu D e p o s i t s ................................. 0595 862 522. 2 I E M 0 R A N D U M - nI£ Bank "A" and Bank "B" have dealings with each other, and Bank '’A11 "receives on deposit" from one of its own depositors a check or draft drawn on Bank "B" and L.imediately credits the depositor's account witn the anount, is there any recognized usage ox custom of hanking which would authorize Bank "A" to simultaneously dehit the amount to the account of Bank "B»?« Answer: "Yes" in some cases and "No" in others, depending on the relation of the banks to each other. In considering t^is question the relations of one bank to another iiUbt be taken into account, for the answer will depend upon the exact airangenent which is a ratter of contract or agreement Detween the banks and may be broadly differentiated under thr^e heads, to wit* (a) where Bank "A" is n large bank m a Reserve or Central Reserve City and Bank "B" a snail bank which use3 Bank "Art as its reserve depositary, (b) ^htire Bank "A" is the little bank m the country and Bank "B" the large bank m the city, sending checks drawn against it for collection, (c) Where Banks "A" and "B" are on terms of equality, they may be banks in different cities, receiving each other’s checks either on the basis of re ciprocal balances, or on the collection basis, carrying no balances. 522. Bank "A11 Bank in a Case (a) Central Be serve or Bank in a NonReserve City or Town Reserve City CASE (a) Under the usual custom, which is of course subject to exceptions by agreement in particular c-ase3, Bank "A” receives from its depositors, whether banks or individuals, checks drawn on Bank ‘'3" which has a reserve account with it, and gives their depositors imr.v9d.iate credit. Bank "A” may receive such checks from some depositors, either bank or individual as the case may be, at par, in consideration of a satisfactory balance carried wdth it by such depositor, and in other cases it may deduct a charge sufficient to com pensate- it for cost of collection and time involved in transit. X£ the depositor be a bank, the credit is usually a bookkeeping entry which does not draw interest or entitle- the depositor bank to draw against it until the checks have actually been collected. As every credit must have a simultane ous corresponding debit, Bank “A” debits daily the stem total of the checks that it i3 sending to Bank ”E 1[ against an auxiliary account known as the ’’transit account”, which debit in turn receives a corresponding credit after Bank ”B” has received the checks and has cade remittance to Bank "A" for them. If this remittance is in the form of a check on some other bank no debit is of course made against the account of Bank nB” with Bank ”A”, but where Bank ”B” advises Bank ”A" that it has credited Bank ’’A ’s” account with the amount of the checks, Bank ”A” credits the transit account and charges the amount against Bank nB'sn reserve account. In effect this is a system of immediate credit and deferred debit, but as between banks at least really tantamount to deferred credit and deferred debit since the immediate credit is not available. The principle governing thi3 arrangement is that Bank "B" is carrying with Bank ”An a reserve account against which it has occasion to draw checks. Bank “B” desires to know-at all tines the exact amount that it has with Bank ”An subject to check, which wouldbe impossible if it per mitted Bank nA" to charge on receipt items against the account.' While, however, this is doubtless the predominating custom today, it is also true {I) that Bank nA” may have, a general agreement with Bank "B” pro viding for immediate debit of items drawn on the lattor, without getting any specific permission in any given case* such checksin soma large banks amount ing to a considerable percentage of t._ tal, and(2) that Bank ”A ” may in some cases where it doubts the solvency cr promptness of Bank ”B ” make im mediate debit writhout getting permission to 4o so. 864 - Bank "A" Case (b) Bank in a NonReserve j City :or Town ; k i | 3 . - Bank "B" 522- Bank in a Central Reserve Reserve City CASE Co) ■ Under the- usual rules, subject to exceptions, Bank "A" when it receives from its depositors checks drawn on Bank MB" or other banks, which by special arrangement it collects through Bank "B" gives the de positor immediate credit and at the same time makes an immediate debit on its own books against Bank "B". This operation enables Bank "A" t^ include the sum total cf these items charged against Bank- ''Bn as part of its lawful reserves. Bank "B'1 of course does not credit these items on the account ox Bank "A” with it until these items have actually been received; and would not make such a credit against telegraphic advice from Bank "An that it was mailing the items. Bank 11B" Bank |;AT1 Case (c} Bank in a NonReserve City or Town i I L j i Bank in a NonReserve City or Town CASE (c) In this case Banks "A" and "B" collect each otners checks and checks on such other banks as may have been mutually agreed upon, on a reciprocal basis. Each bank charges the other with the sum total of the daily re mittance letters and credits the other subject to final payment, with the sum total of items received from the other, making the entry upon receipt. Each account therefore, shows offsetting debits and credits and it fre quently happens that balances are not large either wayAs balances ac cumulate one way or the other, they are usually settled by checknof the debtor bank upon its correspondent in a reserve city. 2/3 /1 6 - k 522. "Assuming that it ware the statutory duty of each Federal Reserve Bank immediately to credit the accounts of its member tanks with the face value of all checks and drafts drawn upon depositors of the Federal Reserve Bank which may be deposited with it by its member banks, could that duty be performed at all or could it be performed consistently with sound banking practice unless the Federal Reserve Bank could simultaneously debit the amounts of such checks and drafts to the accounts of the banks drawn upon? ’’ Answer: _ "No". At the present time the common, but not universal rule of immediate credit and deferred debit results in the case of large banks with many correspondents carrying vhat is known as a "float" amounting, in at least one case which had cone to our attention, to the large total of $1 9 /0 0 0 ,0 0 0 . That %.?■ tc'say there are at any one time book credits aggregating that amount on the books of one bank in excess of the debits which have been charged by that bank against the individual bank corresponding with it. In other words, the banks .in reserve or central re serve cities, tc a considerable extent, carry these book credits in excess of the debits actually charged as an asset, under the title "Due from other banks." However, this is not quite so dangerous a procedure from the standpoint of the bank giving these credits as it would appear in the telling, for the reason that these credits are simply book credits, which banks are not permitted to draw against until collections have beer, made and the offsetting debits charged; and by the same token, interest is not allowed on these accounts until returns from collections have been completed. The real- effect of immediate credit and deferred debit is to make for the depositing banks a. fictitious showing in re serve deposits in the hands of the correspondent bank in the reserve or central reserve city, for 'while the credits are not available to be drawn against, they are counted as book credits and hence as reserves. 2 /3 /1 6 . A GENERAL SCHEME OF CHECK COLLECTION AND CLEARING UNDER THE FEDERAL RESERVE ACT. Washington, February 24, 1916. 1* The Federal Reserve Board may designate every Federal Reserve Bank to act as a Clearing House for the checks of its District. 2. A member bank nay send to its own Federal Reserve Bank for deposit checks drawn on or collectible through other member banks ox the same District, but not checks drawn on banks of other Districts# 3. Every member bank may send to the Federal Reserve Bank of any District for collection and for the credit of its own Federal Reserve Bank checks drawn on or through member banks of that District. This means that a member bank receiving on deposit checks drawn on banks all over the country,will send to its own Federal Reserve Bank the checks drawn on banks of that District, claiming immediate .credit therefor and it will send to other Federal Reserve Banks, for col lection and credit to the account of the Federal Reserve Bank of its own District, checks drawn on banks of the District ot which such Reserve Bank is the head# In other words every Member Bank will make up its checks into twelve envelopes or packages, one for its own, and one for each of the other eleven Reserve Banks. It will send to its own Reserve Bank carbon duplicates of letters transmitting remittances of checks sent for collection and to the credit of its- Reserve Bank,. It can claim immediate credit for items sent to its own Reserve Bank, but only deferred credit for : items sent for collection to other Reserve Banks, U. Under the above arrangement every Federal Reserve Bank will thus be receiving direct from, say 7^00 banks - bundles of checks drawn against its members. Those deposited by its own members are credited at once to the account of the depositing banks and debited against the payer bank, while those sent from banks in other Districts are credited to the exchange account of the Federal Reserve Bank of the District represented by the sending bank and debited simultaneously against the payer bank. 5* A Federal Reserve Bank each night will have on its books amounts representing the aggregate of the above credited items; all of which have been charged against its own member banks; it will wire the amounts of these credits to the various Federal Reserve Banks and receive from these same eleven banks advice of the credits they have to its account. If it is assumed that each Federal Reserve Bank keens with every other Federal Reserve Bank an account for exchange purposes which may run a reasonable credit .or debit either way, it may be assumed that in most cases the resulting debits and credits by these daily balances ’will only have to be settled once or twice a week through the Gold Settlement Fund. a 6. It is suggested that while/Federal Reserve Bank might properly charge nothing to its own member banks for items sent to it and drawn against its own members, it should charge member banks of other Districts a service charge for the expenses of collection and remitting balances to the Federal Reserve Bank of the District to which the sending bank belongs, and this service charge on a reason able cost basis may be charged by the member bank against its customer. 553- - 3 7» The above plan gives immediate credit to the bank for all checks upon banks of its own District., but deferred credit with a service charge for all checks drawn against banks of other Districts. The time of transit however is greatly shortened for the reason that the forwarding bank sends checks for collection direct to each Federal Reserve Bank and should get credit as soon as the Federal Reserve Ba-nk has received the items, charged them against the payer bank and credited them to the Reserve Bank of the District represented by the sending bank. Thus, the First Rational Bank of Columbus, Ohio, sends Cleveland District checks to Cleveland for deposit and claims immedi ate credit, at the same time it sends Chicago District checks to Chicago, St. Louis District checks to St. Louis, etc. These checks reaching these Federal Reserve Banks the next day are charged against the accounts of payer banks and credited to the exchange account of the Federal Reserve Bank of Cleveland. Thus the First of Columbus should be able to claim immediate credit for Cleveland items and, say one day deferred credit for items drawn on the Chicago and St. Louis District Banks; the same for items on Atlanta and Richmond Districts, and proportionately later dating for 8. more distant Districts. The greatest advantage of this method is the direct and simple routing of all items and the consequent reduction of float. Large city banks are now required to send checks for collection to some 500 points whereas, under this plan, they would be enabled to send checks to twelve centers (except of course, local Clearing House items) and the clearing and collecting would be focussed and concentrated at those points with a minimum of delay. , 869 W. P. G. HARDING, GOVERNOR PAUL m . WARBURG, V ic e Go ve r n o r FREDERIC A. DELANO ADOLPH C. MILLER FT f“ ' i CHARLES S. HAMLIN JJL Ex -Offic io Members WILLIAM G. McADOO SECRETARY OF THE TREASURY C h a ir m a n JOHN SKELTON WILLIAMS FEDERAL RESERVE B O A R D COMPTROLLER OF THE CURRENCY WASHINGTON H. PARKER WILLIS, SECRETARY SHERMAN P. ALLEN, ASST. SECRETARY and F is c a l A g en t AD D R E SS R E PLY TO FEDERAL. RESERVE BOARD February 25, 1916- Sir: On January 2 5 , 1916, the Federal Reserve Board, at the request of the Secretary of the Treasury and in accord ance with the provisions of Section l6 of the Federal Re serve Act, requested each Federal Reserve Agent to transmit to the Treasurer of the United States an amount in gold equal to five per cent of all outstanding Federal reserve notes which are covered by a deposit of gold or lawful money. The establishment of a redemption fund by the vari ous Federal Reserve Agents became necessary because of the fact that only four of the twelve Federal reserve banks at that time had outstanding notes covered by commercial paper and only those four 'were required to maintain any credit balance in the gold redemption fund. In those cases when both the agent and the bank have funds to their credit in the redemption fund, the Trea surer legally has the right to redeem notes either out of the account of the Agent or of the bank, but upon request of the Federal Reserve Board he'made all redemptions, whether of fit or unfit notes, out of the Agent's account, delivering tns unfit notes to the Comptroller of the Currency for destruction and returning the fit ones direct to the Agent. This request of the Board m s made partly to insure similar treatment of all fit notes presented to the Treasurer for redemption, and partly to aid in retiring Federal reserve notes by returning them to the Agent rather than to the bank for fufcther circulation. In view of the fact, however, that various Federal Reserve Agents have formally asked the Board that fit notes be returned to the Bank instead of to the Agent, on the ground that such Agent has not the facilities for handling periodic shipments of small amounts of notes, the Board has now formally requested the Treasurer to redeem all fit notes out of the redemption fund of the bank, provided such bank has a credit balance in that fund. If it has no such balance, fit notes will be redeemed out of the Agent’s account and'will be returned to the Agent. Fit notes redeemed out of the Bank's account will, of course, be returned to the bank. All unfit notes, as contemplated by the plan dated January IS, 1 9 1 6 , 870 - 2 55^* will be redeemed out of the Agent’s account and, acting under the power of attorney given to him by such Agent, the Treasurer will deliver such notes to the Comptroller of the Currency for destruction. Any bank which has no money on deposit with the Treasurer and which desires its fit notes returned to it rather than to the Agent may make a voluntary deposit for the purpose of meeting the redemption of those fit notes which are received by the Treasurer for that purpose. Respectfully, Secretary 559. February 22, 1916. My dear Governor: The accompanying letter from Mr. Myron Camp bell, Cashier of The South Bend National Bank, South Bend, Indiana, has been referred to this office for an opinion. Mr. Campbell asks whether in the opinion of this office Section 5211 of the Revised Statutes gives the Comptroller of the Currency power to require National banks to furnish any information other than that which is to be published in the newspaper, and whether the Comp troller may impose the penalty prescribed by Section 5213 of the Revised Statutes for failure to furnish such information. The question of what information may be called for by the Comptroller under the authority of Section 5211 was considered by the Attorney General in an opin ion dated November 9, 1912. In this opinion the Attorney General says "By section 5211, Revised Statutes, the Comp troller is expressly given - 'power to call for special reports from any partic ular association whenever in his judgment the same are necessary in order to have a complete knowledge of its condition1. One view of this section is that it limits the power of the Comptroller to call for reports con cerning the financial condition of a particular as sociation only, and that it is not broad enough to empower him to ask reports regarding general condi tions which may have a bearing merely upon the ex pediency of amendments to the existing law. I think that too narrow a construction of the section, be cause section 333, Revised Statutes (above quoted) requires the Comptroller to make an annual report to Congress at the commencement of its session, showing among other things, 'any amendment to the laws re lating to banking by which the system may be improved and the security of the holders of its notes and other creditors may be increased', and the power given in section 5211 to call for special reports is, in my opinion, broad enough to authorize him to call for any reports which may be necessary to enable him to de termine how, in his opinion, the banking system may "be improved, by new legislation and what legis lation he should recommend to Congress for that purpose". It seems clear, therefor§, that the Comptroller is not limited to the statement showing the financial condition of the bank which is published in the newspaper, but may call for any information which is necessary to enable him to determine the true condition of the bank. Section 5213 refers specifically to failure to furnish information called for in Section 5211. In the opinion of this office, therefore, the Comptroller could impose the penalty prescribed for fail ure to furnish the information called for. Respectfully, M. C. ELLIOTT, Counsel. Honorable Charles S. Hamlin, Gove rnor. March 1, 1916. My dear Sir: On February 29 the Federal Reserve Board gave final consideration to the appeal of certain Connecticut banks for transfer from District No, 1 to District No. 2, and it was agreed to transfer Fairfield County, Connecti cut, to District No. 2, (New York), the remainder of the territory covered by your petition and appeal to be left for possible cons ids nition at some future time, when more experience with the clearing system shall have been had. I enclose a copy of a pross notice which wa3 approved by the Board, and states the situation. Action has been taken with reference to effect ing the transfer of the banks in Fairfield County, and the Federal Reserve Banks of Boston and Now York will take the matter up direct with the institutions which are affected by the transfer. Respectfully, Secretary. 874 562. STATEMENT FOR THE PRESS. February 29, 1916. The Federal Reserve Board today voted to grant the appeal of certain Connecticut bankers for the transfer of territory west of the Connecticut River from District No. 1 to District No. 2, in so far as relates to the banks situated in Fairfield County,, adjoining New York State. Action as affecting the balance of the territory covered by the petition was suspended, a majority of the Board not being as yet ready to dispose defin nately of the appeal, pending more complete development of the clearing system. / 3 2/16 875 567. A BILL TO LIMIT THE USE OF THE WORD “FEDERAL". BE IT ENACTED BY THE SENATE AND HOUSE OF REPRESENTATIVES OF THE UNITED STATES OF AMERICA IN CONGRESS ASSEMBLED. That all hanks, other than Federal reserve hanks, created and organ ized under an Act ol Congress approved on December 23, 1913, and known as the Federal Reserve Act, and all firms, partnerships or corporations doing the business of bankers, brokers, or savings in stitutions, and all insurance, indemnity and trust companies, are prohibited from using the word "Federal" as a portion of the name or title of such bank, corporation, firm or partnership, and any violation of this prohibition.committed after the first day of January, 1916, shall subject the party charged therewith to a pen alty i y dollars for each day it is permittod or repeated, PROVIDED, however, that this prohibition shall not apply to corpor ations organized prior to December 23, 1913, under titles which in- . elude the word "Federal" or to firms or partnerships doing business prior to that- date under such titles. A 3/8/16. 7‘*o 568. AMENDMENT TO SECTION 22. BE IT ENACTED BY THE SENATE AND HOUSE OF REPRESENTATIVES OF THE UNITED STATES OF AMERICA IN CONGRESS ASSEMBLED. That that part of Section 22 of the Act approved December 23, 1913, and known as "The Federal Reserve Act”, which reads as follows: "Other than the usual salary or director's fees paid to any officer, director, or employee of a mem ber bank and other than a reasonable fee paid by said bank to such officer, director, or employee for services rendered to such bank, no officer, director, employee, or attorney of a member bank shall be a beneficiary of or receive, directly or indirectly, any fee, commission, gift, or other consideration for or in connection with any transaction or business of the bank", be amended and re-enacted so as to read as follows: "Other than the usual salary or director's fee paid to any officer, director, or employee of a mem ber bank and other than a reasonable fee paid by said bank to such officer, director, or employee for ser vices rendered to such bank, no officer, director employee, or attorney of a member bank shall be-a beneficiary of or receive, directly or indirectly, any fee, commission, gift, or other consideration for or in connection with any transaction or business of the bank, PROVIDED, HCWEVER, that nothing in this Act contained shall be construed to prohibit the. payment of reasonable fees for services rendered by an attorney to a member bank who is a director of said bank, or prohibit a director, officer, or employee from receiv ing the same rats of interest paid to other depositors for deposits made with such bank, and, PROVIDED, FUR THER, that notes, drafts, bills oi' exchange or other evidences of debt executed or endorsed by directors of a member bank may be discounted with such member bank on the same terms and conditions as other notes, drafts, bills of exchange or evidences of debt upon the affirmative tote of three-fourths the members of the board of directors of such member bank". 3/8/16. 87? 569. BE IT ENACTED BY THE SENATE AND HOUSE OF REPRESENTATIVES OF THE UNITED STATES IN CONGRESS ASSEMBLED, That Paragraph 31 of Section 4, of the Act approved. December 23, 1913, and known as the Federal Reserve Act he amended and reenacted so as to read as follows: ’•Class C directors shall be appointed by -the Federal Reserve Board. They shall have been for at least two years residents of the district for which they are appointed, one of whom shall be designated by said board as chairman of the board of directors of the Federal reserve bank and as 'Federal reserve agent,' He shall be a person of tested banking ex perience; and in addition to his duties as chairman of the board of, directors of the Federal reserve bank he shall be required to maintain under regulations to be established by the Federal Reserve Board a local office of said board on the premises of the Federal reserve bank, Re shall make regular reports to the Federal Reserve Board, and shall act as its official representative for the performance of the functions conferred upon it by this Act. He shall receive an annual compensation to be fixed by the Federal Reserve Board and paid monthly by the Federal reserve bank to which he is designated. Qne-ef-the-direet&rs-ef 61a8s-Gj--whe-sh&ll-be-a~pereen-ef~tested-banking-experieHeey-shall-be-appeiBted-by-the-FedeFal-Re&erve Beasd-as-deputy-ehairmaH-aBd-depHty-Federal-reserve ageBt-t9-exeFeise-%h&-pewearS-e£-the-ehaiFKa»-e£-the beard-aBd-Pederal-Eeserve-ageBt-iH-ease-df-abseBee ©p-dieaMlity-e^-his-prineipal". 3/8/16. 586 MEMORANDUM —of— Various £or Clearing Plans the and Collection of Checks. Submitted to the Federal Reserve 3O 0 Washington, D. C. March 21,1916* Board. 880 586 PLA N N 0 . 1. Plan of cneck collection and clearing recommended by a. Comautteu of Federal Reserve Agents CMesers. Martin, Curtiss and Jay) unaer date of October 13# 1915/ and enu bodied in a report of the Committee# printed in full m the Federal Reserve Bulletin for November 1915# Pages 3^9-372* 1* That as soon as practicable., and under arrangements w m c h will make clear and restrict its use to the purposes for which it w&3 establisred# settlements through the gold settle ment fund snould be made daily* 2 That the Federal Reserve Banks should soon arrange to undertake the collection of notes and drafts# and of items drawn or. no^-member ba?k3 upon the most favorable terns which can be arranged in tie respective districts. 3 That the Comptroller should be asked to endeavor to arrive at an agreement *vith all State bank supervisors that on and after a giver date checks m the mail shall not be counted 2.0 reserve That through mutual agreements# oach Federal Reserve Bank should receive checks drawn on members of the collection system of every other Federal Reserve Bank# deferring credit for ther a sufficient number of days to ?llow them to reach the Federal Reserve Bank of the district of origin# plus the number of days# if any# allowed by such Federal Reserve Bank to reach 586 - a - the paying tank; and further That through nutual agreement* any Federal Reserve Bank r may receive lor immediate credit che.ck3 drawn on members of the r collection system of any other Federal Reserve Bank; and that whenever it is froth practicable and more direct* member banks in 3uch collection systems may send direct to the Federal Reserve Bank of the district of origin instead of to their own Federal « Reserve Bank. 1 That the^development of inter^distrjet collecting need not await the'*completion of the intra-djstrict collection systems. That' in extending the collection system both within and across district lines uniformity need not prevail but .instead there should be freedom and flexibility of rules and requirements in order that each reserve bank may best meet the conditions and \ needs of its member banks. " That each Federal Reserve Bank should retain the right to change immediate credit points ’to deferred credit'points* to assess upon members the cost of its collection service* to make charges against its member banks for using their balances to create exch?Jige on other districts* and generally to' make such rules and regulations as will enable it promptly to safeguard its position 2nd protect itself against unsound development. 883 5$6 -a •P L A N N 0 2 Plan for Chock Collection Adopted by the Executive Committee of Governors at a reeting on October 2 3 , 19^5* submitting,, witn slight alterations a plan previously adopted by the Transit Managers of the Reserve Banks* The Fifth Conference of Governors at the morning session, Saturday, October 23rd, 1915* considering the further development of the collection systei , "adopted as its recommendation the sub stance of Vote 12, of the Transit Managers1’ Conference of October 6th and 7th, 1 9 1 5 * as representing substantially its views on this subject, and laft to the Governors1 Executive Committee the de velopment of the details of the plan and its submission to the Federal Reserve Board with power to invite the attendance at any meetings of such of the transit men of the different banks as the committee may select.11 In order that you may be advised of the principles adopted as the basis upon which the plan outlined m Vote 12, mentioned above was drafted, I enclose copies of the minutes of the Transit Managers1 Conference with notations" m Ink showing such changes as were made by the Conference of Governors, except that a typewritten slip is attached giving the vote of the Governors Conference adopted m lieu of Vote S of the Transit Managers1 Conference. RECOMMENDATIONS TO EXECUTIVE COMMITTEE BY THE TRANSIT MANAGERS Morning, afternoon and night sessions were held on October 6th ana 7 th. The deliberation of the Conference resulted in the passage of the votes recorded below, every representative being 881 5*56 - a* - 2 - present when each vote was taken., except that in one or two cases representatives absent for a fow minutes authorized the Secretary to record their votes: 1* Voted - That we heartily favor every extension of the ^ operation of a check collection system consistent Concurred in by Governors with sound principles and permissible under the Federal Reserve Act. 2, Voted - The deliberations of this body are based on the assumption that every member bank is required by Concurred m by Governors lav/ to cover at par all checks and drafts drawn upon it received from the Federal Reserve Bank of which said bank is a zpember. 3* Voted - Immediate debit and credit not required* *'r. Pike of Atlanta a&ked to be reported as voting nN o ." • That the Federal Reserve Bank should have the privilege at its discretion of accepting check? Concurred m by Governors. on any bank, banker or trust company. a Voted - Unanimously carried. We recou* end that the actual expense of handling items on non-member banks shall be assessed by the Concurred in by Governors. Federal Reserve Bank against the member depositing such itens with the Federal Reserve Bank. Unanimously carried. 5* Voted .» That consideration of a service charge by the Federal Reserve Ba.nks Concurred m by Governors .or collection of checks on member bank? deposited with the Federal Reserve Banks be deferred at this time. Carried without a dissenting voice _ 6 . Voted - 3 _ _ 586 - a. WHEREAS, Section l6 of the Federal Reserve Act stipulates that Federal Reserve Banks shall accept at par from their member banks checks and drafts on their members, this Conference recommends to the Governors* Conference that this provision of the Concurred m by Governors* Act be developed by the several Federal Reserve Banks on a deferred credit and deferred debit basis, but we believe that the privilege to handle items on an uuediate debit and credit basis, so far as expedient to do so, should be granted. Carried. Mr. Pike voting ’*No", explaining that the Atlanta directors are on record as being opposed to putting into effect any system of clearing on a par basis. 7• Voted - That items sent to Federal Reserve Banks should not be counted as reserve until credited by the Federal Reserve Bank, but in computing reserves the total Concurred m by Governors. amounx of sucn items may be deducted from the member banks' gross demand deposits. Unanimously carried. 8. Voted - Substituted by Governor* That anjr plan for the interchange of checks between districts should apply only to those banks vtfiich do not impose restrictions as to endorsements. Unanimously carried. 9- Voted - We recommend that the matter of transfers of funds for member banks between the several Federal Reserve Banks be handled on the basis outlined by the Gov ernors of the Federal Reserve Banks at their recent Conference until such time as the intraudistnct 884 536 - U - Concurred in by Governors. - a. clearing facilities are developed to an extent which '•will justify a reconsideration of this question* Unanimously carried. 10. Voted - It is the sense of this meeting that transfers of funds between any two banks in- any Federal Reserve Concurred in by Governors. District should be made by means of direct order rather than by checks and drafts. Unanimously carried. 11. Voted - Concurred in by Governors. That the j.irec interchange of items between members.. by settlements through the Federal Reserve Banks be encouraged. Unanimously carried. 12. Voted - We recommend to the Executive Committee of the Governors’ Conference that a system of Inter-District Collection be inaugurated at once as follows: Each Federal Reserve Bank will accept from any of its member banks for deferred credit and deferred debit a.t par, in accordance with the provisions of Section l6 of the Federal Reserve Act, checks and drafts on member banks in any of the other Federal Reserve Districts. Each Federal Reserve Bank will agree to accept at par .from other Federal Reserve Banks checks and drafts on its own members for credit a certain number of business days after the receipt of such checks and drafts, said number of days to be based upon the average length of time necessary to obtain returns from its members. Upon 885 886 - 5 - 586 - a. receipt of advice from the other Federal Reserve Banks as to the number of days determined as aforesaid each Federal Reserve Bank will prepare a schedule of deferred credits applicable to checks on other Federal Reserve Districts deposited by its members. Every Federal Reserve Bank operating on a deferred debit and deferred credit basis within the district will in* elude In said schedule of deferred credits indication of the number of days for which it will defer credit to its members of checks and drafts on other members in its district. Each Federal Reserve Bank will, if possible, avoid having more tnan tnree classes of deferred credit, and will request its member banks to sort items in accordance with the number of days for Much credit I.* deferred, and to list in one letter all the items for which credit will be deferred the same number of days, furnishing th6 Federal Reserve Bank a separate letter for each cl?ss of deferred credit, as well as another lotter m Much will be listed all items to be accepted for immediate credit. Debit against a i.eirber bar^s account of checks and drafts drawn upon it will be deferred for the same number of days for wnich credit is deferred in accepting such items from other members of the district. Letters of transmittal to member banks will show plainly the date on vdiich the items listed therein vail be 887 . 6- 536 - a. charged to the member hank's account. Each letter of transmittal to a Federal Reserve Bank will show / "plainly the dato on which credit is expected in ac cordance with the schedule of deferred credits, and „ will he charged to the Federal Reserve Bank on 3aid date. In order to guard against tne great congestion in cident to taking on at once a large increase in the volume pf items, the plan should he developed in progresoive stages hy beginning with checks, each one of which anounxs to $1*Q00 or more, and gradually reducing the limit as to the amount of each check until the limit can he safely removed* Changes m said limits shoaid he identical in all districts both as to the amount and the aatc on jhich the change is made effective. Nothing in the foregoing shall he construed as prohibiting any Federal Reserve Bank from continuing to handle such items as it is now receiving. In order to shov how schedules of deferred credit may he made up in each district, there 13 herewith submitted a tentative schedule applicable to checks deposited (See Exhibit MAM) in the Federal Reserve Bank of Chicago by its members. In accepting checks from other Federal Reserve Banks, Chicago will give immediate credit for checks on mem bers of the Chicago Clearing House Association, and 888 t - 7 - " 536-a- will defer for two days credit of checks and drafts on other hanks in its district. This plan contemplates that Federal Reserve Banks particularly may. adopt short-cut methods for eliminat ing time in receiving credit. For instance, if Chicago accumulated a large volume of items on Seattle, it would expect to send such items to Seattle for account of the Federal Reserve Bank of San Francisco, after agreeing with San Fraacisco as to a basis of deferred credit for our Seattle letter 889 5*6 - a. EXHIBIT SCHEDULE p? DEfERRED CREDITS FDR DISTRICT NO. 7. ' Illinois TWO DAYS. (Except Chicago Clearing House Banks - inarmedlate credit) Indiana and all Federal Reserve Cities except San Francisco. Iowa Michigan Wisconsin FOUR DAYS. Alabama Maine North Dakota West Virginia Arkansas Maryland Ohio Colorado Massachusetts Oklahoma Connecticut Minnesota Pennsylvania Delaware Mississippi Rhode Island District of Columbia Missouri Florida Nebraska South Carolina and San Fran~ eisco, California* South Dakota Georgia New Hampshire Tennessee Kansas New Jersey Texas Kentucky New York Vermont Louisiana North Carolina Virginia , EIGHT DAYS. Arizona Nevada Washington California (except San Francisco) New Mexico Wyoming Idaho Oregon Montana Utah 890 -5 86-b- P L A N g, A PLAN T O R CLEARING AMD COLLECTING-CHECKS BY FEDERAL RESERVE BANKS. (Suggested by Mr.W, S, Rowe of Cincinnati,Ohio) Every Federal Reserve Bank would send a circular to its members stating that it proposed establishing a Clearing House, Department ( as required to do by the Federal Reserve Board, acting in accordance with the terms of the Act) for its members, accepting from its members and from any member bank in any other district, any item on member banks in its own district, and to charge for that service, a rate based both upon the volume in thousands and the actual number of items handled to cover its expenses, such rate to be determined by experience and then fixed by rule of the Federal Reserve Board. On the other hand, the Federal Reserve Banks would state in the circular that they proposed paying each member bank for the service rendered by the member bank whose items sent £o the Reserve Bank Clearing House had been offset against items on the member bank. This charge also would bo determined by experience, to be based upon ths volume in thousands, and would then be fixed by rule by the Federal Reserve Bank. These rulings as to charges would undoubtedly vary from time to time, depending upon conditions and seasons, * *91 l - 2- The circular would then recite that if any member bank proposed sending items on member banks, bearing the endorsement of a non-member b a n k , the service, chargg, would be at a higher rate, as non-member banks either directly or indirectly, should not reap benefits at the same cost as the member banks. And further, any member bank, desiring the privilege of having checks of a neigh boring non-member bank treated as though such checks were drawn upon it, might apply to, and this application might be granted by its Federal Reserve Lank.' The rate of compensation to the member bank for clearing these items and the rate to be charged for col lecting items on such non-member banks f or whom arrangements as above had been made, would also be fixed by rule, but these rates would be higher than member bank check rates, thus operating as an additional reason why non-member banks should join the system, as ultimately it would .cost a merchant more to collect .items on non-member banks, than.to collect items on member banks, and more . , to deposit items in a non-member bank than in a member bank, if this plan lecomes operative in its fullest extent. Under this plan, we for example, the First National Bank of Cincinnati,Ohio, would arrange to have checks drawn on a given list of non-member banks treated as though they were checks on ourselves, and after the Cleveland Lank had completed making such arrangements covering every non-member bank in the district, it would mail an announcement saying that it was prepared to accept through its clearing house department, any items on non-member banks, as well as any items on any of its own member banks, the i 3- ■'586“b,‘ charge* and payment to member banks to be determined later, as outlined above, and that it v/ould credit or charge each member bank's account at the day's clearings, with the difference be tween the items sent through the clearing heuse, and the items received at the clearing house. It is manifest that these operations of the clearing house department would not affect in any way, the total deposits of the Bank, as credits and debits would .equal. In the banking department .however, a credit from the clearing house department might be immediately withdrawn, while a debit might even overdraw another account. To provide for this, rules in regard to main taining a deposit in the Clearing House Department, to cover items to and from'the Reserve Bank, should be promulgated,based \ upon fairness to the member banks and safety to the Reserve Banks. The proportionate relation between volume of items on and col lected for a bank, to its required reserve, should affect the size of the clearing balance. Inasmuch as similar notices would have now been sent out by the other 11 Banks, we would receive one from each of the other 11 Banks, stating that each Federal Reserve Bank would re ceive items in its Clearing House Department from any member bank or any bank in the district, and atating that each Federal Reserve Bank would take from any member bank^outside af its district, any items on member banks or non-member banks, and that it would remit, after deducting a fair charge, to the send -4 -586-b- ing Bank's Reserve Bank for its credit. This remittance would then be credited to the account of the member bank by each R e serve Bank when received, subject to a slight charge, and as the settlement between the tv/elve Reserve Banks at the olose of each day would be large, they might even be cleared as between themselves by telegraph each afternoon, and adjustments made through the main Clearing House of the tv/elve banks, at the '( office of the Federal Reserve Board, through the gold fund al ready created. From a practical point of view^ we would then write a letter to each of the tv/elve Reserve Banks, instead of writing as we do now, more than 500 letters, and would list items very much the way we do when sending items to Chicago, drawn on many different places. Chicago does not demand now that we sort •ur items based upon4the places ef payment, and we can see no reason v/hy the Reserve Banks should, as they should be able to sort an immensely larger volume of items than the ones we would send, at a lower cost, and we would be paying our pro portion of such cost. Our endorsement on such items should read : "Cleared through federal Reserve Bank of ____ _ J' followed by our name and the date sent, as well as the date it should fe cleared unless letters are delayed in transit, and accordingly the actual date of clearing changed. endorsement would fee necessary. No additional Our entry on our books would be t ; 895 -5- ^ -586-b- to charge each Reserve Bank with the total of our letter, and in figuring reserve, our balance at Cleveland would be counted, while the amount of the total letter sent to the other Banks would not be reserve. This other total,however, v/ould undoubtedly not equal the total of our present balances in St.Louis, Chicago,New Orleans, New York, Albany, Boston, Baltimore, etc., even after allowing for such balances as we would wish to continue to keep in larger cities for exchange and other purposes. If telegraphic remittancewas a rranged for with each of $he other eleven banks, we could make the entry on our books covers ! * ing letiB rs sent today as follows: v/e could charge Cleveland with • the total of the letters to Richmond, St. Louis and Chicago after one day; New York, Philadelphia, Boston, Kansas City, etc. on the etc., second day, and finally San Francisco/on the fifth day. Obviously tlie accumulation of such letters in transit before they reached their destination would hot' bo vjry large. Return items might be handled in two ways, either through the Reserve Bank which had previously cleared them, or direct to the memlber bank. Experience would show which banks would be more usually creditors at the daily clearing, and which banks would more usually be debtors, and the rules suggested heretofore in regard to main taining of balances on the books of each Reserve Bank could only be promulgated so as to-be fair, after experience reached through a trial. Banks having customers apt to check unusually heavily should prepare themselves, and might well v/atch thejfcr larger ac- A: -586-bcounts; and such action would be in the interests of good banking. This plan then contemplates,although many details are omitted or only inferred, the establishing in each Reserve Bank of the fol lowing departments; (I) Clearing House Department, in which all items on the district are cleared and in which department suitable and fair excess balances must be maintained. (II) Exchange Department. in which department the twelve Reserve Banks would clear as between themselves, and also clear the credit turned over from the resultant , credit-«$f a member of another district, whose checks on that district had been cleared in Department I. (ill) Banking Department, in which only currencv and drafts on itself would be accepted at par, and the resultant credit or debit after the days clearing in Department I would only-be credited or charged to the member banks reserve account in this department, after deciding that the clearing balance in Department I was satisfactory. The Banking Department would also include the other functions of discount, examination,etc. Thus the charges in Department I vjould be fairly large, based upon total in dollars and total number of items, and would also be reciprocal to cover expense incurred in restoring balances. J ' . Charges in Department II would to smaller and charges in Department III would btr nil, in so far a 3 " cash items" are con cerned. Cf course, "collections" as distinguished from "cash items'1 could easily be handled upon a cost basis in either De partment I or Department III. 3/20/16 897 586 ~ P L A N N 0. 4i A COMPOSITE OF VARIOUS SUGGESTIONS FOR CHECK COLLECTION AND CLEARING UNDER THE FEDERAL RESERVE ACT. Predicated on the theory that the practical and perhaps tho legal requirements demand that a check,, bping an order to pay cash at the counter of the Payee Bank, must be sent to the Payee Bank and be in the hands of that bank before it can be charged against it and credited to the Depositor. 1.* Under Section 16 of the Federal Reserve Act, the Federal Reserve Board nay require each Federal Reserve Bank to act as a Clearing House for checks drawn on banks of its District. In vie// of the further transfer of reserves on liay 16tb, the Board has set June 1, 1916, as the date when these functions shall be unr dertaken in a complete manner. Every member bank handling many checks shall send in twelve separate envelopes, one to each Federal Reserve Bank, checks against banks of its respective district; provided, however, that a bank having less than, say fifty items for any given district may if it prefers send those items to its own Fed eral Reserve Bank for sorting and transmission. 3. Checks on banks in the same city clearing house district shall be given one day deferred credit and debit but all. other checks in same district shall be given two days deferred credit : and debit, unless the one-way time shall exceed that amount, in which case deferred credit and debit, equal to the one-way time, shall be fixed. 898 _2 4. 5^6 - c Checks on hanks in other districts must he given a minimum deferred credit and dehit of two days and an increment over this i£, and hy as much as the one-way. time from the send ing hank to the Federal Reserve Bank of the district on which check is drawn, plus the time from that Federal Reserve Bank to the payee hank, exceeds this two days. 5. Banks sending checks to Federal Reserve Banks of other districts shall claim credit for their own Federal Re serve Bank Exchange Account, sending duplicate of letter of transmittal to their own Federal Reserve Bank. 6. Nothing in the above shall prevent hanks in neighbor ing cities sending checks direct to other hanks provided that time is saved hy so doing; thus Rochester, N. Y. and Buffalo, N. Y.; New Haven, Conn, and Hartford, Conn, might interchange checks on any mutually satisfactory basis if by doing so time is saved and float diminished. 7. The Federal Reserve Board will authorize Federal Reserve Banks to charge their own members as follows: per item plus 10# per thousand on all collections made for sending hanks; at the same time, the Federal Reserve Board will authorize member hanks to charge Federal .Reserve Banks or other member hanks, sending checks for collection, 10# per thousand upon all items sent. tlements to he made monthly. Set These charges, subject to modifi cation on sixty days notice, are intended to cover approximate average cost of remitting cash or exchange to meet halanflos or reserve requirements. 899 - 3 - 8. 5^6 - c Menber banks will be authorized to make collections of State bank items m their own town or within a convenient radius of operation and will be authorized to charge for this service the amounts above quoted or a3 much as the actual cost of the service should it exceed this amount - all such rates to be approved by the Federal Reserve Board. 3* Under the above arrangement every Federal Reserve Bank may be expected to receive direct from perhaps 3;000 banks bundles of checks dravn against its members. Those deposited by its own members are credited to the exchange account of the District repre sented by the depositing banks and debited against the drawee bank, according to the time schedule above referred to, while those sent from banks in other districts are credited to the exchange account of the Federal Reserve Bank of the district represented oy the send ing bank and debited simultaneously against the drawee bank. 10. A Federal Resexve Bank each night will have on its books amounts representing the aggregate of the above credited items, a.!} of wnich have been charged against its own member banks, it will wire the amounts of these credits to tne various Federal Re serve Banks and receive from these eleven Reserve Banks advice of the credits they have to its account. If as is assumed each Fed eral Reserve Bank keep3 with every other Federal Reserve Bank an account ijor exchange purposes which may run a reasonable credit or debit either way, it is safe to eay that m most cases tne result ing debits and credits by these daily balances will only need to be settled once or twice a week through the Gold Settlement Fund. - 11 586 - c k - The above plan gi\e* deferred credit and debit to the bank for all checks outside the home city starting with two days, but not beyond that in exces* of the one-way time between districts, plus the one-way time from toe Federal Reserve Bank of the drawee bank to that drawee bank. The time of transit i* greatly shortened as compared with the methods commonly in vogue by reason of the direct routing and of uaing tne twelve Federal Reserve Banks as clearing houses, each a focussing point for the checks of the district. Tnu*, the Fir*t National Bank of Columbus, Ohio, will send' ito Cleveland District checks to the Cleveland Reserve Bank for dopooit, tlaiiiii/ig immediate credit two days later, at the same time it 3ends Chicago District checks to the Chicago Reserve Bank, St. Louis District checks to the St. Louis Reserve Bank, etc. Theoe checks reaching these Federal Reserve Banks the next day sent to the drawee oanks and m most cases are charged the following day again*t the accounts of the drawee bank and credited to the exchange account of the Federrl Pescrve Bank oi Cleveland Thus the First National Bank of Columbus will c l a m two days deferred crediT for Cleveland items and, m mo*t case3, two day* deferreo credit for items dravo on banks m the Chicago, St Louis, Atlsuta and Ricrmond Diotncts, and proportionately later datings for more distant'..Districts It is safe to say teat a very large proportion of the business of the country m check clearing would be done on a two days deferred basis12 The obvious advantage of this method is the direct and simple routing of all iteri3 and the consequent reauction of float, hlhereas large city banks are now required to send checks for collection to some 500 points, under thio plan, they would 901 - 5 - 5 g6 - c • be enabled to send checks to twelve centers, and perhaps five or six other points with which the interchange of checks i3 con siderable. Generally speaking, the clearing and collecting of checks is by thi3 plan focussed and concentrated at twelve Federal Reserve Banks with a minimum oi delay. At the same time small country banks would be given the privilege of sending all their checks regardless of the district on which drawn to their Federal Reserve Banks, or to some correspondent bank for collection and credit. 13. The reason it is not necessary to defer debit and credit beyond the one-way time may be thus illustrated: for the sake Let us suppose, of an argument, that the Federal Reserve Bank of Chicago sends to its Agent at Des Moines all the items drawn against Des Moines Banks. That agent presents the checks next morning at the various banks and draws out cash or takes a credit on the local b a n k13 books. Having thus accumulated in the five local banks, say $250*000 in cash or credits, he wires or tele phones the Federal Reserve Bank of Chicago of the fact. The Fed* oral Reserve Bank of Chicago replies that it has itself received in checks sent by Des Moines banks against Chicago hanks items aggregating $260,000 and that it is, therefore, not necessary for the Des Moines agent to remit any cash or exchange, because the drawings on Des Moines are more then offset by the drawings on Chicago; in fact'that Chicago must send Des Moines $10,000 as a balance. However, as the amount is small and the balance may -,6 - $S6 - c * may be reversed the next day, it ib agreed between the agent and principal that the brlance in favor of Des Moines shall be allowed to stand. It will thus be seen that thio plan of credit and debit deferred to equal tne one-way ti„e a.&'its the principle that the payee bank 3hall see iters drawn against it before having these items charged against its reserves and enables it, if any of these iters are unusually large, to nake a special arrangement by wire or telephone to meet them. 3/20/16 ✓ 903 586 - d. P L A N N 0 . 5. Memorandum and Plan submitted by the Governor of the Federal Reserve Bank of Dallas, Texas, under date of March 15, 1 9 1 6 , for the Clearing of Checks under sdiat may be des ignated as the Talley System of Offsets. After careful consideration of all suggested or proposed plans for a clearing or collection system which have come to our notice, the officers of the Federal Reserve Bank of Dallas are firmly convinced that none can ever be adopted vtfiich will be ac ceptable to the member banks or satisfactory to the Federal Re serve Banks unless it be based upon a system of offsets, or what is known as the clearing principle in use by all of the local clearing houses of this country. The Cashier of the Federal Reserve Bank of Dallas, Mr. Lynn P. Talley, has made a thorough study of the details of such a plan and an outline of the fundamental details of the restiit of his study is presented below. with the plan of operation m This plan is not to be confused use by the Boston Country Clearing House and other similar Country Clearing Houses which are nothing more nor less than Joint Collection Agencies. Some of its advantages are as follows: (1) An immediate debit and credit system would of neces sity, frequently impair and destroy reserves and place upon the Federal Reserve Banks such a burden of "float" that their usefulness would be seriously impaired. On the other hand a deferred debit and credit system would place upon the member banks the entire burden > 904 _ 2 - 5*6 - d. of "float", without offset, on which account it would he used only to a very limited extent. The plan proposed is, in effect, an immediate debit and credit system to the extent of the amount of offsets, with a minimized deferred debit and credit of only the amount of the resultant balances, which deferred debit and credit is equitably distributed# (2) This plan provides for the payment of items by the drawee bank only at its counter and after it has inspected (3) the items# The. reserve balances of a member bank with the Federal Reserve Bank are debited only at the direction of said member bank, which therefore has knowledge at all times of the condition of its reserve. (U) The cost is minimized and is equitably distributed among the banks receiving the benefit of the transfers of funds necessary to complete the settlement. (5) • The plan of apportioning returns to the creditor, banks in the order of their size (Section 2 (e)) is based upon the axiomatic principle that one day's interest on $10,000. is equal to five days' interest on $2,000., and is the mo3t equitable manner of facilitating settlements. x x x x x x x :: x We were so sure of the practicability of this plan that on Monday, December 27, 1915> we inaugurated, in the Federal Reserve Bank of Dallas, a "Reserve City Clearing House", made up of the thirtythree member banks in the six reserve cities of this district, which has proved the success of the plan and has been so satisfactory to the participating baftks that it is still in operation and will be - 3- 586 - d continued until superseded "by some plan promulgated by the Federal Reserve Board. The total amount of items cleared through this Reserve City Clearing House from December 27, 1915# to March 15/ 19^6, was $85,6 3 7 ,6 0 2 .9U, with resultant balances amounting to $20,97*+UI8 .U2 . Of this amount of balances $0,87*+,900. of the debits were settled through deposits of Eastern Exchange; $3,108,000. by deposits of currency; $7,088,518.U2, by instructed debits against reserve balances in this bank; while $1 ,903,000. was settled by arrangements between debtor and creditor banks in the same city. We believe that a careful study of the following outline will convince any one of the practicability and simplicity of the plan. OUTLINE OF FUNDAMENTAL PRINCIPLES OF THE TALLEY PLAN OF CLEARINGS The plan proposed contemplates a Federal Reserve District Clearing House, and each Federal Reserve Bank, in handling clear ing items for its members through its Clearing House Department shall act as agent only and shall not become responsible in any manner whatever for delinquency or default of any member. It is proposed that each Federal Reserve Bank shall in augurate a Clearing House Department along the following lines: (1) The Clearing House Department shall clear for the member banks of its district checlcs and drafts drawn upon zi\r other member bank of the same district except such 905 906 506 - d. _ U - as are drawn by or endorsed by banks which are not members of the Federal Reserve System. (2) The total of items received from a member bank shall be credited to 3uch member on the credit aide of the Clearing House balance sheet. The total of items received against a member shall be debited to such member on the debit side of the Clearing House balance sheet. Resultant balances between “Items received" and "Items sent" fren and to a member bank will be settled from each de.y*s settlement sheet in the following manner; (a) All items received through the Clearing House on a given member will be forwarded immediately to said member, properly listed and totaled, which list shall be made in dupli cate and shall show from whom received. The duplicate list shall be a part of the Clearing House records. (b) The Clearing House shall forward to each member interested in the day's clearings a slip showing total of items received from thafc member, total of items sent to that member, and the resultant credit or debit balance due to or from that member. (c) The Clearing House shall prepare and send to each * member receiving a debit balancd in the day's clearings a settle ment check for the amount of such debit balance, which check shall be drawn against the reserve balance of such member in the Federal Reserve Bank and shall be payable to the District Clearing House. (d) This check shall be immediately 3igned by the 907 - 5 - 5^6 - d- proper officer of the member bank and returned to the Clearing House to be apportioned among the creditor banks. If the payment of this settlement check would reduce the reserve account of the member bank below the required amount, it shall be the bounden duty of such member bank to accompany said settlement check with a deposit of acceptable funds sufficient in amount to make good the required reserve. (e) The amount of the first settlement checks received from debtor banks shall be apportioned to the bank receiving the largest credit balance in the clearings of that day, then to the second largest, and so on down, each creditor bank receiving credit in its reserve account for its credit balance as soon as settlement checks sufficient in amount have been received and paid by the Federal Reserve Bank. (f) Clearings 3hall be made on each business day, and neither debit nor credit balances may become cumulative, but each day's clearings must be settled separately. (g) Advices of all debit balances amounting to twenty- five thousand dollars ($2 5 ,000) and over will be telegraphed to the owing bank. (h) When, in order to meet it3 settlement check only, it becomes necessary for a debtor bank to ship currency to the Clearing House, said debtor bank shall be entitled to and receive the actual minimum cost of transportation from its office to the Federal Reserve Bank of such currency actually shipped, providing advice of such cost accompanies the settlement check. Such cost SOS _ 6 - 5S6 - d. shall he credited to the* reserve account of the shipping member and shall be proportionately charged to the reserve accounts of all mem bers clearing items on the shipping member on that day. (i) Debtor banks., in order to prepare their reserve ac counts to meet their settlement checks, may make remittances in. New York, Chicago ar St. Louis exchange at the rate promulgated by the Federal Reserve Bank for such exchange. (j) Settlement checks must be signed and returned to the District Clearing House on the same day they are received by the debtor bank. (k) In the event a member bank receiving a debit balance in the District Clearing House fails to pay such debit balance promptly, or fails to provide funds in its reserve account with the Federal Re serve Bank to meet its Clearing House settlement checks, or sus pends payment and is placed in the hands of a receiver, or otherwise becomes unable to meet its obligations on demand, or is otherwise insolvent, then the Federal Reserve Bank shall proceed as follows: The amount of all items on such defaulting bank, which are in the process of collection or have been sent to such drawee or defaulting bank and for which payment has not been received by the District Clearing House, shall be credited to the District % Clearing House, and the amount oi each item included in such credit shall be charged to the reserve account of the member bank endorsing said item to the District Clearing House Department* (3) Member banks may, if preferred, send their items to any other member bank situated in the prevailing direction such items 909 - 7 - would take m may then* m 586 - d their natural course of collection* and items so sent turn, be sent to the District Clearing House Department of tne Federal Reserve Ban!* but m Bank receive m no case m i l the Federal Reserve its Clearing House Department items bearing the en dorsees Tt of more tnan two member banks. (lj>) Unpaid items received from the Clearing Hou©e shall be returned direct by the drawee bank to the bank endorsing same to the District Clearing House* and a debit ticket for the amount shall be cleared on such endorser through the Clearing House* carbon dupli cate of such debit ticket being attached to the returned unpaid items. These tickets will be m certificate form and may become a part or all of the remittance to the Federal Reserve Bank to cover a Clear ing House debit (5) A slip giving the name of the sending bank and directing wire advice of non-payment must be attached to each item of $1*QG0 or over at the time it is sent to the Clearing House De partment* which instructions must be followed by the drawee baztfc. (6) All items of over ten dollars ($10 ) must be sent subject to protest if not paid. (7) The expense of maintenance ana operation of the District Clearing House Department shall be borne by the member banks by paying* on the first of each month, two cents for each item cleared during the preceding month until it io determined by experience what is the actual cost per item. When this has been determined 3uch actual cost shall be paid (g) The plan shall be promulgated by tne Federal Reserve 910 - S_ 586 - d. Board and shall be mandatory under the provisions of Section 16 of the Federal Reserve (9) Act. Such general rules and aodifications of rules as may be necessary m the operation of the plan may be promulgated by the Federal Reserve Board from time to time V 3/20/16. 911 -586-f- SUPPLEMENTAL TO PLAN NO* 5 SUBMITTED BY MR. LYNN P. TALLEY,CASHIER OF FEDERAL RE SERVE BANK OF DALLAS. 0 O0 The fundamental principles upon which any clearing plan which might be adopted must be based ; First. That the face of a check and the back.of a check are entirely different propositions. Granting that a check is payable at the counter of the drawee bank and that it is not incumbent upon the drawee bank to transport the funds to the point where the holder resideSiat an expense to the payer. The holder of a.check at a point different from the place of payment receives the check for value and determines its v^lue at the time the check is received and it is then incumbent upon him, either with or with out previous knowledge of conditions, to convert the check into funds that he c m use. Second. That the interchange of items between banks under present methods perhaps increases the float two or three fold. Briefly, because a bank concentrates its items with various other banks of its own selection and the receiving bank must, of course, stand the burden of float in conversion. A large proportion of these checks received must be collected by sending them to banks which will, send the last endorser a remittance drawn on still another bank, perhaps in another city, with which it concentrates its items for balances through its own choice. There is then a float created in collecting returns which have been sent in for original items. Third. That this choice of correspondents is largely a matter of individual right and need not be necessarily disturbed by breaking off relations of years standing by being compelled to collect miscellaneous items through the Federal Reserve Bank. Therefore, the plan provides that a member bank may sefad its items to another member bank which may, in turn, d e posit them with the Federal Reserve Bank for credit in the Dis trict Clearing House, provided such items bear no more than two member banks' endorsements,including its own, and the prevailing direction of collection which the item would naturally take is not violated. You can readily see that this would permit the country banks to continue to send their items to city banks which would have facilities available for collecting them through the Federal Reserve Bank. ~2- Fourth. To minimize the float referred to in (1st) by the system of offset under the clearing principles; that is to say, the float would be reduced to collecting the difference between itei$s sent and received at the District Clearing House, which I venture to Say 'would be somewhere in the neighborhood of 20 to 25/1 cf the total volume cleared* In addition there would be a float equal to thjg transit time between the location of the member bank and tne Feoer^l Reserve Bunk, which would be equitably distribu ted between the member banks and involve only their own itemf* This float, however, could be appreciably* reduced by member banks sending item? received in volume on any one point direct to the urawee member banks at that point and sending us a copy of the letter* Fifth. Exchange charges have not been taken into con sideration in the revised plan submitted in view of the clear intent of the Act to abolish exchange charges to the point of only actual expense involved in the transportation of funds. Since, technically, exchange charges axe based on shipments of the actual amount of currency representing the difference in the balance of trade, the cost, under the plan proposed, would be reduced to a final minimum as remittance would in volve the settlement of only the difference between items sent and received. You can see, therefore, that I have sought to reconcile conditions- existing heretofore with the new order of things to the extent that I believe the plan fairly over comes the objection of the member banks in giving up their ex change charges by providing them with the most economical facili' ties at the Federal Reserve Bank for the collection cx items rather than issuing a mandate that member banks must clear their items through Federal Reserve Banks* Sixth* It is very natural that any plan suggested would emanate from some large Reserve or Central Reserve city institution.;- by reason of its wide experience in receiving and collecting miscellaneous items or by suggestion of one who had had broad experience along this line in these larger insti tutions. 3/a/i6 913 5S6 - e. P L A IT P 0 . 6^ A PLAN FOB CHECK COLLECTIONS BY FEDERAL RESERVE BANKS. (Submitted by Mr. Ray M- Gidney of the Staff of the Federal Reserve Board) Preliminary Statement In the consideration by those connected with the Federal Reserve Banks of the problems connected with the establishment of check collection service by Federal Reserve Banks, there has been substantial agreement that the greatest difficulty to be met is that involved in carrying "float" represented by checks in process of collection, which might have to be assumed by the Federal Re serve Banks. "Float" in this sense may be defined as the exten- tion of credit which takes place when credit is given for a check in advance of its actual payment by the bank upon which it is drawn. Its magnitude is measured by the amount of checks in transit at any one time, and the "float" for a single item is its amount multiplied by the number of days which must elapse before it i§ collected. The question of who should carry the "float" must be con sidered and dealt with before any plan of check collection can safely be put in operation. Three parties may be recognized in this trans action; the payer of the check, the payee, and the agency through which the payee attempts -to collect the item. sented by the bank The payer is repre upon which the check is drawn, the payee by the bank which receives the check on deposit in first instance, and the collecting agency by the bank which is used as an intermediary in the collection of the check, in the present situation the Federal Reserve Bank. One of these parties must carry the float. The general practice now is that parties receiving the check in first instance carry the float. A firm or individual receiving a check and depositing it in a bank is required to keep a balance which will justify the bank in handling and collecting the check , and as a rule is not allowed to withdraw the funds in advance of collection by the bank. The bank which thus receives an out of town check must in turn carry the "float" whether it sends the check direct to the pay ing bank or sends it through.a collecting bank. it is not permitted In the first case to charge the bank upon which the check is drawn until the latter has received the check and given authority for the charge. Even if the check is collected through such an * J institution as the Boston Country Clearing House, the bank does not get its money until two days have elapsed. If the bank attempts to collect the check through another bank it does not receive real credit until the check is collected, although it gets an immediate credit in appearance, but must keep a "reasonable" minimum balance on deposit with the correspondent and rhust not draw against items until they are collected. The Executive Committee of the Conference of Governors has recommended that a Federal Reserve Bank, if it is to act as a collecting agent for it3 member banks, shall not carry the float. The reasons urged are that to the extent that a Reserve Bank does so, it impairs its power to meet the requirements of its members for re discount facilities, and that the amount of the aggregate float of the country is so large as to absorb power of the Federal Reserve Banks. almost the Entire loaning The Governors also point out 5S6 - e -3- the difficulties to be encountered if it is sought to have the paying banks carry the burden. Member banks upon which checks are handled are required to maintain excess reserves equal to the amount of checks in transit to them from the Federal Reserve Bank during two or more days' business; they have no very exact means of estimating the amount of checks which are thus in transit and overdrafts are likely to occur with possibility of loss to the. Federal Reserve Bank. The Governors do not,however,, except in connection with their proposed plan for deferred debit and deferred credit, appear to consider the possibility of leaving the burden ox carrying the float where it is; namely with the bank which has re ceived a check on deposit in first instance and therefore has it to collect as best it can. If a method can be found whereby the Federal Reserve Banks can successfully perform the check collection functions clearly con templated by the Federal Reserve Act, without carrying the float in volved, it is obvious that they should not carry the said float. There is doubt as tc whether they are able to assume the burden of the float without seriously impairing their loaning power and even if they are able to do so they should not grant the credit extension involved without proper remuneration. They are corporations deal ing in credit and should not give ax,-ay in any form the goods which it is their business to sell. At the same time it should not be the problem of the Ftoderal Reserve Banks to determine whether the float shall be borne by the banks upon which checks are drawn or by the banks which have received the checks upon deposit. This is 916 -4- 586 - ©• a matter of general business arrangement with which the Federal Re serve Banks are not directly concerned. The purposes of the Act will be carried out and the usefulness of the Federal Reserve Banks greatly increased if they are able to provide prompt collection at par of checks drawn on member banks and prompt collection, with a moderate exchange charge of checks drawn on non-member banks in cities where there are also member banks* To this end the following plan, combining features of both the immediate credit and debit and the deferred credit and debit plans, and based upon the assumption that member banks can be required to remit promptly at par for checks on themselves sent to them by the Federal Reserve Banks, is submitted: Details of Proposed Plan. Each member bank will carry ‘'clearings account1 .1 the books of its Federal Reserve Bank, in addition to its reserve account. All deposits of checks drawn on member banks will be credited to the depositing banks in their clearings accounts and charged to the member banks upon which the checks are drawn, in their clearings accounts. The depositing banks will be permitted to draw against the balances resulting from deposits of checks on other member banks only after a suitable time has elapsed to permit collection of offset of the items. The length of time which it will be necessary to delay such withdrawals will vary in the different districts, reaching, a maximum in the San Francisco District, and can be finally determined only after some months of experience in the operation of the planTo start with sufficient time should be allowed for the checks to reach the paying banks and a remittance in payment to be received in » -5- return. 586 — 9• The immediate result of this operation will be that the depositing banks will have credit balances and the paying banks overdraft balances, and as the overdraft balances will just off set the credit balances „ it v/ill not be necessary to maintain a reserve against the latter. In the case of a district in which practically all banking points can be reached by mail in one day the banks which acquire credit balances m i l be permitted to with draw any portion of such balances representing deposits made two days or more previously . In this way, even assuming that the pay ing banks have not themselves made deposits of checks on Other member banks and thus become creditors as well as debtors, they will re mit funds in time to.meet the withdrawals permitted so that over draft accounts will not exceed the credit balance accounts. If, however, the banks which we have been considering as the paying banks are constantly mailing checks to the Federal Reserve Bank for deposit, their remittances will arrive in such manner as to offset the checks against them and thus reduce the time of float by one-half. To what extent this will occur can of course only be determined from the actual operations of the clearings system, but it is certain that the offset principle will be operative to a very large extent as operations become general. Through this reduction in the time of float the average time which must elapse before a member bank can draw on a deposit will be proportionately shortened. This matter of offset is of greatest importance and in it lies the superiority of the plan which is given here over the plan under which the Boston Country Clearing House is now operating and over the plan _6 5S6 - e. of deferred credit and deferred debit proposed by the Governors of the Federal Reserve Banks. It is much as though the New England Country Banks instead of awaiting receipt of their checks from the Boston Country Clearing House and then drawing a draft on a Boston correspondent bank in favor of the Clearing House for the amount of the remittance, were to send daily to the clearing house all checks on Boston which they might receive in the course of business instead of sending them to Boston correspondents against whom they later issue a draft in payment.for the checks received through the clearing house. It is clear that if this were done the effect would be to shorten by one-half time required for the collection of checks sent out by the Boston Country Clearing House. The following example will illustrate the ..operation of offset, the first column showing a case in which offset is effective and the second column a case where it does not operate and in which, as with the Boston Country Clearing House and the Governors' plan of deferred credit and debit, a return remittance must be awaited. A member bank in Philadelphia deposits vsith the Federal Reserve Bank of Philadelphia on a certain day for credit in its clearings account, checks.aggregating $?5.*000 on a member bank in Harrisburg, Pa. action: The following will be the course of the trans 919 5 S6 -7- With offset* On the same day the Harrisburg member bank mails to the Federal Reserve Bank of Philadelphia for deposit in its clearings account, checks on the Phila delphia member bank amounting to $25,000.00. Entries will be as follows: Day of remittance: - a. Without offset. 'On the following day and upon re ceipt of the remittance the Harris burg member bank issues and forwards to the Federal Reserve Bank of Phila delphia, its draft on the Philadelphia member bank, for $25,000-00. Entries will be as follows: Dav of remittance: Philadelphia member bank charges Federal Reserve Bank of Philadelphia, $2 5 ,0 0 0 . Philadelphia member bank-charges Federal Reserve Bank of Philadelphia $2 5 ,0 0 0 . Federal Reserve Bank of Philadelphia credits Philadelphia member bank, $2 5 ,0 0 0 . Federal Reserve Bank, Philadelphia credits Philadelphia member bank, $2 5 ,0 0 0 . Federal Reserve Bank of Philadelphia . Charges Harrisburg member bank $25,000 Federal Reserve Bank of Phila. charges Harrisburg member bank $2 5 ,0 0 0 . Harrisburg member bank charges Federal Reserve Bank of Philadelphia $25,000. First dav following: Harrisburg member bank receives remittance from Federal Reserve Bank and credits account of the latter $2 5 ,0 0 0 . First dav following: Harrisburg member bank receives remittance from Federal Reserve Bank and sends in return draft on Philadelphia member bank $25,000. Federal Reserve Bank receives re mittance from the Harrisburg member bank and credits account of the latter,$2 5 ,0 0 0 . Federal Reserve Bank charges Phila delphia member bank $2 5 , 0 0 0 and delivers by messenger the drafts, etc., received from the Harrisbutg member bank. Philadelphia member bank credits Federal Reserve Bank $25,000 for items thus received. Transaction closed. ■, Co1le ct ion example, continued • _____________ Without offset. Second dav following: Federal Reserve Bank of Phila delphia receives remittance from Harrisburg member bank and credits account of the latter, $25 >000 . Federal Reserve Bank charges Phil member bank and delivers messenger the? draft received from the Harrisburg member bank. Philadelphia member bank credits Federal Reserve Bank $25>000 for draft thus received. Transaction closed. Reserve status of clearings accounts. Such portion of the balance of each member bank in its clear ings account es is available for withdrawal may be counted as reserve, for it can at any time be withdrawn or transferred to the regular reserve account, but such portion as is not available for withdrawal should not be so counted as it represents uncollected items. Neither should the Federal Reserve Bank to required to hold reserve against the portion of the clearings accounts representing uncollected items,but it should be required to hold reserve against that portion which represents items which have been collected and are therefore subject to withdrawal at any time. It will be objected by seme that the credit given to member banks which deposit items in the clearings account will not be "immediate credit". This is true, but the credit given is certain to be more nearly immediate than would be give?i under the deferred debit and credit plan proposed by the Governors, which Joes not contemplate offset, of 5S6 - e. - s - of items but apparently treats each remittance as a unit for separately* to be settled It will also be more nearly "immediate credit" than is given to banks which collect through the Boston Country Clearing House and than that given by check collecting banks which do not per mit withdrawals until the item is collected and which dp not _uti1ize the practice of offsetting; items* It would be well to provide that the credit may be made immediate in fact as well as in name by per mitting a member bank which wishes to withdraw a balance created by deposit of items on other member banks or to count such balance as reserve, before the items have been collected or offset, to do so by paying interest thereon at the rate in force for discount of short term pa,per* In such case the Federal Reserve Bank would assume float to the amount involved but would be properly reimbursed for so doing* Prompt remittances at par are essential to the successful operation of this plan* Where a bank does not remit' promptly an interest charge at the rate current for short-term paper should be assessed against it for the time of such withholding on the amount of items upon which prompt remittance is withheld* Chocks on non-member banks* It is quite generally agreed that checks on non-member banks must be handled by the Federal Reserve Banks in order to make the check collection system completely successful* This step should be taken at once in connection with the £ian here submitted and with the cooperation _ 10 - of member 'banks. 5^6 - . e. Arrangements can doubtless be entered into with most member banks under which they will handle checks on non-member banks in their respective cities and towns at a charge of five or ten centa per hundred dollars, such charge to be computed on the total amount of such checks sdnt in a remittance letter. Checks on non-member batiks in cities where there are also member banks, may then be received by the Federal Reserve Banks just as checks on member banks will be, but subject to a collection charge of five or ten cents per hundred dollars. This plan will doubtless prove sufficiently remunerative to the member banks handling the checks and will result in many State banks entering the system. The facilities which the Federal Reserve Banks will thus be able to offer will greatly exceed those offered by any country clearing house. Inter-district clearings. Inter-district clearings should be undertaken very soon after the inauguration of the plan herein outlined. Checks and drafts on member banks in other Federal Reserve Districts should be taken on the basis of the transit time between the Federal Reserve Cities plus the average transit time between the Federal Reserve Bank of the paying district and the member banks upon whom the checks are drawn. Drafts on Federal Reserve Banks should be credited immediately at par. This may appear to be a disregard of the problem of float, but when it is considered that each Federal Reserve Bank has a heavy deposit in the Gold Settlement Fund and that the acquisition by one Federal Reserve Bank of a draft on another Federal Reserve Bank gives control of a 933 n «, 5^6 ©* corresponding portion of the Gold Settlement Fund, it is apparent that drafts should he regarded as cash by all Federal Reserve Banks. In order to -make this as apparent as possible daily settlements should be at once adopted on the basis suggested in the report of the Preliminary Organization Committee and more lately by Mr. W* E. Cadwallader. The credit effect of making such drafts acceptable for ipmediate/at par by all Federal Reserve Banks will be to give them currency and make them the preferred form of remittance within the United States. Thio will of course be of advantage to the Federal Reserve Banks in many ways, one of which will be that there will at all times be a large credit float in the form of drafts outstanding on Federal Reserve Bankj, which will be more than sufficient to offset any possible burden of float which might fall upon the Federal Reserve Banks by reason of cashing or crediting immediately drafts drawn on each other. The amount of such drafts in transit from the drawing banks and not yet presented to a Federal Reserve Bank would be always greater than the amount in transit between the Federal Reserve Banks for the reason that the time of such float would be at most the mailing time between the Federal Reserve Cities concerned and would be further shortened by offset, while the time required for drafts to reach Federal Reserve Banks other than that upon which drawn v\rould be at least the mailing time between the districts involved and usually longer. 3/21/16. 924 5bo -f PLAN N 0 . I MEMORANDUM AND SUGGESTIONS ON THE SUBJECT OF BANK RESERVES AND THEIR RELATION TO THE SUBJECT OF THE CLEARING AND COLLECTION OF CHECKS (Submitted by Mr. Frederic H. Curtiss, of Boston) Under date of March 2S, 19It * The reserve of a "bank is that percentage of its deposits that it should carry uninvested to meet the demands of its depositors. There axe tiro kinds of reserve; nornan reserve, and excess or in surance reserve. The normal reserve of a bank should be based on the maximum demand of its depositors in normal times. An excess or insurance reserve is the reserve set aside tc meet abnormal or un usual demands; that is a sort of insurance fund. Reserves should bo real; that is, cash in a bank’s own vaults or a deposit in a Federal Reserve Bank. The character of the de posits of a bank varies the percentage of reserve needed. The character of a. bank’s deposits are as follows: Savings accounts; - require small reserve, Individual or personal accounts; - require a higher reserve than the preceding, Commercial accounts; - require a higher reserve than the preceding Bank accounts; » ” " !> ” 11 ■ ’’ There are two kinds of normal reserve: 1. 2. To meet ordinary counter demands, Reserves tc be carried at an exchange center to furnish exchange to its depositors, either in the form of checks drawn by the bank on that center, or by exchange created by customers sending their own checks afar. As icr the reserve for counter purposes,, a bank can gauge its own counter demands and can be trusted to keep cash on hand to meet them. The reserve to be kept elsewhere must be proportionate to its exchange transactions; that is, either the demand of its customers for checks on an exchange center (e.g. Federal Reserve city) to be used in paying bills elsewhere, or exchange created by its customers through paying bills elsewhere with their own checks. This outside reserve, therefore, pertains chiefly to two kinds of bank deposits; viz., commercial and bank. The excess reserve, that is, the reserve for insurance purposes should be held in a Federal Reserve Bank and should be based on all the demand deposits of a bank and the per centage, therefore, should be based somewhat upon the character of the city or town in which the bank is located. In connection with the composite plan of clearing (i.e. Plan 4) the following problems arise. 1. 2. 3. 4. 1. The figuring of reserves, Those arising from deferred credit and debit, Charges for service and exchange, The handling of checks on non-member banks. The figurine of reserve. Although this plan by direct routing of checks originating ^putbic^a of the district, will materially reduce the float on those bhe country bank will never be satisfied to maintain its re serve on a deferred basis plan, and besides, the bookkeeping called for is too intricate for the country bank; hence we roust make up out 926 -586-f- - 3 our minds to allow country bank3 to figure their reserve as they do now, from their o-wn books. By so doing, the reserve bank will re ceive additional balances from the outstanding checks drawn by the country bank on it, and by time items which it has collected and \ credited, and which the country bank will not debit on its books until advice is received. It will be the duty of the Comptroller of the Currency to see that every member bank maintains its re serves by its own books up to the ‘ requirements of the legal min imum* On the other hand, the member bank, both in the Federal Reserve city and elsewhere in the district, must carry its ''excess? legal reserve with the Federal Reserve Bank of its district, this reserve account being figured from the books of the Federal Reserve Bank, the member banks being obliged each week to send in a state ment of their net liabilities so that each Federal Reserve Bank can see that the proportion of reserve is maintained. In other words, this is, as we have said, in the nature of an insurance fund and this reserve the Federal Reserve Bank must 3ee is maintained. 2. Those arising from deferred credit and debit. In the case of immediate credit and immediate debit: we are troubled with: a. b. The question of overdrafts, The question of float. In this connection it is to be noted that the overdraft and float are analogous when taken as a whole and not as they per tain to the individual bank. On the other hand deferred debits and credits involve complications distasteful to small banks. It has been customary,, under the note circulating system to require a redemption fund at some central point to take care of notes circulating throughout the country, as, for instance, under the National Bank Act the 5fo redemption fund in Washington. The circulating of bank notes is similar to that of bank checks except the latter circulate faster, and, therefore, requirs a larger re demption fund. If w 3 f'an cause each bank outside of a reserve city to maintain a redemption fund proportionate to what is ascertained to be its normal clearings, we shall have solved the problem. of these funds will readily take care of the float. plish our purpose if we allow member banks The total We can accom interest on excess balances> a rat? lower than the going rate allowed on bank balances, and which would, therefore, induce the country banks to transfer their surplus balances to the city banks, at the same,'time charging 2$ interest on current overdrafts, current overdrafts being for the day's business, and charging one-half of cno per cent above the cur rent bank rate or. overdrafts that a bank has had time to cover. This excess reserve which serves as a x-edemption fund, will only pertain to banks outside the Federal Reserve cities, and would be for clear- i- c;$7„ ing purposes, v.- 11.. banks ir- the Federal Reserve cities would be enabled to make good their clearings by cash in their own vault? or by buying ana selling exchange, or by rediscounts with the Fed eral Reserve Bank. 3. Charges for service and exchange. It is proposed that Federal Reserve Banks, shall handle all member checks at par, each member bank being charged a rate per item based on the cost of the collection department of each Federal Reserve Bank, but on some general rule to be promulgated by the Federal Reserve Board. Under the Federal Reserve System the cost of exchange is re duced to a minimum; members of a Federal Reserve Bank are able to create exchange by rediscounts with its own Federal Reserve Bank and such exchange will to current throughout the United States. In this connection it may be necessary to differentiate between drafts on a Federal Reserve Bank and exchange transactions. That certain small country banks are living off the exchange charged on their own checks does not appear fair. An exchange charge, if one is made should be t assessed against the drawer; nor maker of the check and not the receiver and depositor of a check. Furthermore, it should be against public policy to allow a collection charge to be made by a member bank against its own checks, 4. The handling of checks drawn on non-member banks. There is no reason why the Federal Reserve Banks should not agree at the outset to accept non-member checks on all Federal Re serve cities on terms similar to checks on member banks in Federal Reserve cities, for those checks can be presented at the counter. Checks within the district on non-member banks remitting at par to the Federal Reserve Bank should be handled on a deferred basis sim ilarly to member checks on other districts and here again a member bank might send those checks to the Federal Reserve Bank of its own district,,giving immediate credit on its own books and count then as reserve, the Federal Reserve Bank handling this item similarly to items on other districts. Checks on non-member banks in other districts, .outside of Federal Reserve cities should be forwarded through the Federal Re serve Bank of the District of origin only as collection itetw for deferred credit. In connection with the handling of non-member checks within the district on certain specifiedypoints, arrangements might be made, •where the trend of exchange warrants it, that non-member checks might be cleared through specified member banks; that is, charged to the account of a member bank and forwarded for presentation and collec tion by the member bank. B00KKEEPIH3 UDDER THE COMPOSITE P L M . (PlInT) 1. Record books of member banks, 2. Record books of Federal Reserve Banks. It is proposed that each member bank shall keep only one account on its ‘books with the Federal Reserve Bank, as it does now with it3 city correspondent, debiting at once to that account all cash items that it sends for collection whether to its own or to other Federal Reserve Banks, and debiting time items only when ad vised of their payment by its Federal Reserve Bank. The member bank will figure its reserves, therefore, from its own books on the basis of this account. On the other hand, the Federal Reserve Bank shaj.1 main tain two accounts with each member bank, the reserve account and the exchange redemption account. The reserve account will be comparatively inactive and will be adjusted either weekly or monthly as a member bank's net deposits increase or decrease, the account to be based on the average for the preceding period. The exchange or redemption account will be maintained only by banks outside of Federal Reserve cities, (banks in the Fed eral Reserve cities being able to redeem or settle for their checks by cash from their own vaults or through the sale of exchange or the making of rediscounts.) This exchange or redemption account will be the active account which the member bank outside of the reserve city will draw against; to which cash items within the district will be credited upon receipt; and cash items drawn on other districts and time items will be credited when paid. This account will be credited with interest on balances and charged interest on overdrafts irre spective of the reserve account. be sent daily to the member bank. A statement of this account will 931 -53 6-;.. S U P P L E M E N T ARY An arrangement might be made with non-member banks along the following linos: 1. Non-ipember banks might be permitted to have their checks redeemed or settled for by a member bank in a Federal Reserve city, on a plan similar to that of member banks ir. Federal Reserve cities. 2. We might allow such non-member banks to print some statement or announcement that their checks were handled with Federal Reserve Banks without charge for exchange. 3. We might restrict member banks ir. the Federal Reserve cities .handling of non-member bank checks through the Federal Reserve Banks only to the check of banks which have agreed to this redemption plain,, endorsing or stamping on the checks some device stating that fact. 932 5 S6 PLAN NO. - g 8 SUGGESTIONS SUBMITTED BY THE GOVERNOR OF THE FEDERAL RESERVE BANK OF ATLANTA, UNDER DATE OF MARCH 2k, 1916, FOR THE CLEARING AND COLLECTION OF CHECKS- FIRST: I would suggest that the officers of the Federal. Reserve Banks he authorized to inaugurate a clearing house, which I believe they have a right to do on the approval of your Board, as set forth in Section l6 of the Federal Reserve Act. I also note that the cost of operating a clearing house under these conditions, can be charged into expenses against the banks using the clearing house. SECOND: I suggest that credits be deferred for two days within each of the Federal Reserve districts for checks collectible in the district and deposited by the member banks; and that from four to six days be allowed as deferred payment for chocks payable in the other Federal Re serve Bank districts, according to distance. THIRD: That an Inter-District system be created between the Federal Reserve Banks similar to the clearings now taking place in the gold fund. FOURTH: That the Federal Reserve Bank be permitted to receive on the endorsement of the member banks, checks on State banks, private banks, savings banks and trust companies, as ,/ell as on their member banks, which I think is covered by open market transactions, as set forth in Section lU. 933 ■' L - 2 536 - FIFTH: That the Federal Reserve Board establish a zone system as to the allowance for exchanges, and for the experimental stage, would suggest the following: On checks drawn on hanks in towns or cities up to 3,000 in habitants, according to the last census of the United States, and to be changed at each census period, that the bank to viiom these checks are sent for collection be permitted to charge l/S of 1$ for the re mittance of such items. (My conclusions for this arbitrary stand, is that the National Bank Act permits banks to be organized in places of this size with a capital of $2 5 ,0 0 0 , and this size bank is dependent largely upon collection charges on checks to sustain their expense account.)* m On all towns or cities, subject to the same rule of the census, of 3,000 up to 10,000 inhabitants, the banks be permitted to charge l/lO of 1^ for remittances and collections. That banks in all towns or cities of 10,000 up to 25,000 inhabitants be permitted te charge 50# per $1,000 on all collections a and remittances. That all towns or cities above 25,000 inhabitants collect checks at par. That the Reserve Bank be authorized to charge the depositing bank the cost of exchange as above referred. That in the event no member bank is located in a town or city, then the Reserve Bank may choose a State bank, trust company, savings bank or private bank, located in that town, to whom it may send the items - g. 934 - 3 - 586 - g. drawn on that town,, provided said "bank will agree to collect at the said rate. In the event no bank not a member, be willing to collect at these rates, then the postmaster in that town be authorised to col lect these checks, deducting as remuneration the same fee as would be allowed to the member bank thus located. SIXTH: That the overhead cost of collecting these items be deter■J mined by two units; one unit to be the aggregation of the total face value of the items handled, and the other unit to be for the number of items handled. An equalization between these two should determine the charges .to be made for this service. SEVENTH: * That the Federal Reserve Bank should determine when the item had reached its maturity of deferred payment, and immediately credit the same into the reserve account of the member bank thus producing the credit, and correspondingly charge transit account with the same. EIGHTH: That the Federal Reserve Bank shall not be responsible for the loss arising from any item, and shall not be held responsible until it has received ultimate final payment for said item. U/6/16 935 536 - h. PLA N N 0 . .2 PLAN SUBMITTED BY MR. GEORGE 0. BQRDWELL, CASHIER OF THE FEDERAL RESERVE BANK OF SAN FRANCISCO, UNDER DATE OF MARCH 2U, 1$ l6, for the CLEARING AND COLLECTION OF CHECKS, WITH IMMEDIATE CREDIT AND DEFERRED DEBIT PROTECTED BY INTEREST CHARGE ON FLOAT. Federal Reserve Bank to receive, for immediate credit and deferred deb.it checks and drafts upon any member bank or non-member bank (Federal Reserve Bank carries member banks’ Transit Account but is protected by deposit of optional reserves) Interest charge at higher than 30-day discount rate to be made to depositing banks on amount of outstanding items minus excess of reserve deposits over required reserve deposits (Member bank carrying with Federal Reserve Bank excess deposits equal to full amount of float pays no interest) Time schedule for interest charge to cover average time by States, "San Francisco, immediate, California three days, Oregon five days, . . . . etc........ (Great advantage to San Francisco Banks) Exchange paid by Federal Reserve Bank to be debited back to depositing banks. Transportation charges to be paid by Federal Reserve Bank on shipments to cover excess collections forwarded by Federal Reserve Bank to banks which remit at par. Service charge on interdistrict cash items say £0^ per $1,000 on intradistrict. .c&sh items rate based on actual cost in- 936 _ 2 - 5^6 - h. eluding transportation charges, not retroactive. say \§<? per item on collections - - — (Reduction of cost to member banks in operation of their Transit departments should largely offset total service charges) Transfer drafts and special items received for deferred credit. The plan suggested will: make it advantageous for member banks now collecting own out-of-town items to deposit them with Federal Reserve Bank (see illustration) make it practicable for all member banks to route items through Federal Reserve Bank permit banks to control their balances give incentive to carry excess balances with Federal Reserve Bank, at least to the extent of optional reserves which in amount ap proximate estimated float protect Federal Reserve Bank from extensive involuntary loans through check collections. ILLUSTRATION: (applicable November 191? to member banks now collecting own items) A member bank now handles $'4,030,000 cut-of-town items in one month; California $3*000,000; Oregon $500,000; Washington $450,000; outstanding 3.» 5 and 7 days respectively Average items outstanding - - — - - Reserve requirements now reduced by deducting float from-bank deposits - - - - $75,000 Required reserve deposits - - - - - $505*000 600,000 - 3- 586 - h. Optional reserve deposits - - - - - - - — Reserve requirements to cover $LOO,O0O increase in net bank deposits would be increased - - - boo,ooo 6 0 ,0 0 0 Total unproductive funds, member bank collecting own items - — 1 ,5 0 5 ,0 0 0 9 0 -day discount rate - - - - - - - — - Rate of interest charge on collections---- 6 fp WITH FEDERAL RESERVE BANK COLLECTING ALL ITEMS: Unproductive funds reduced to — — - - - — If only minimum balance maintained, interest charge - - - — - - - - — If balance increased by deposit of optional reserves interest charge ~ ■ — - - — — 1 ,0 6 0 , 0 0 0 - - - - If additional deposit maintained of $105,000 interest charge - .— - - - — - - — - unproductive funds - - - - - - - - — - - 2,735 569 none Gain in loanable funds through Federal Reserve Bank collecting items - - - - - - - - - - - - - - 165*090 3U0,000 RESULTS: Member bank, by routing items through Federal Reserve Bankj. increases loanable funds $3 ^0 , 0 0 0 at same time, avoids interest charge of $2 ,1 6 6 by depositing with Federal' Reserve Bank optional reserves otherwise unpro ductive, at same time, avoids interest charge of $569 through excess deposit of $1 0 5 ,0 0 0 to cover remaining items, (this deposit only necessary when float exceeds optional reserve) is encouraged by lower discount rate to borrow by rediscounting rather than through failure to maintain latter deposit. 938 - u- 586 - h. DEFINITION; Plan I " w " " *' ” 2 2a 3 3a 3b U Proposed by Federal Reserve Agents Optional Proposed "by Governors Mandatory Deterred credit and deferred debit Now partially operated in District 12 Optional Deferred credit and deferred debit Proposed by Messrs. Rowe & Davis Mandatory Immediate credit and immediate debit Now partially operated in District 10 Mandatory Immediate credit and immediate debit Now partially operated in Districts Optional $ Composite of suggestions Mandatory " " * 5 $ 7 Deferred credit and deferred debit with option of immediate credit and immediate debit. Now partially operated in District 11 Proposed by Ray H. Gidney Mandatory Proposed by Geo. 0. Bordwell 4/7/16 Immediate credit and immediate debit Deferred credit and deferred debit limited to one-way time for points more than one day distant Immediate offset for each bank’s incoming and outgoing items with deferred credit and deferred debife for resultant balances Deferred credit and deferred debit with float pro-rated and loans authorized at current discount rate Immediate credit and deferred debit protected by interest charge. - 5 - 5S6 - h, ITEMS HANDLED: 1 proposes to handle a p o rtio n of items on member banks and a l l on S ta te hanks; 2 , 3 a, U & 5 p rovid e fo r h a n d lin g item s on a l l member banks; 2a & 3b p rovide f o r h a n d lin g a p o rtio n of the member bank item s; 3 .’proposes to handle a l l member bank and some S ta te bank item s; but to make d isc r im in a to ry charges a g a in s t S ta te bank checks> 6 proposes to handle a l l member bank and some S ta te bank item s; 7 proposes to handle a l l item s. THE FLOAT: 1 2 & 2a 3, 3a & 3b le av e s burden w ith d e p o sitin g banks* except when immediate c r e d it and debit a v a ile d of; leave burden w ith d e p o sitin g banks; attempt to pass burden to drawee banks; a c tu a l r e s u lt s : O ve rd ra fts and depleted b a lan ce s a t Federal Reserve Banks; 1+ le a v e s burden w ith d e p o sitin g banks fo r one day item s and w ith Federal Reserve Bank or drawee banks fo r retu rn t r i p on more d is ta n t item s; " 5 d is t r ib u t e s burden in u n c e rta in and c o n sta n tly v a ry in g pro p o rtio n s between endorser banks, drawee banks and other banks which are n e ith e r endorsers nor drawees; 6 attem pts tc p ro -ra te to d e p o sitin g and drawee banks with perm it to withdraw p ro -ra te d average o u tsta n d in g funds a t current d iscou nt ra te s; 7 p la c e s r e s p o n s ib ilit y d ire c t upon F e d e ral Reserve Bank but o ffe r s d e p o sitin g banks e ffe c t iv e inducement to ca rry excess d e n o sits to cover. CONTROL OF BALANCES; .1, 2, 2a & 7 perm it member bank3 to c o n tr o l t h e ir balances; 3; 3®1 & 3b do n o t g iv e member banks c o n tr o l of t h e ir balances; k, $ & 6 http://fraser.stlouisfed.org/ r Federal Reserve Bank of St. Louis g iv e member banks o n ly p a r t i a l c o n tro l of t h e ir balances; 840 - ’ h 6 - 5 S6 - h EXCHANGE CHARGES: 'i on member bank:iw;less to discuss pending legal'decision or checks : legislation either requiring drawees to cover at par or authorizing exchange debited back to depositing banks1 accounts; 8n State bank plans 3 and S propose flat rate to be paid all checks : drawee banks to debit of depositing banks’ accounts plan 7 leaves open question of paying exchange but provides for debit to depositing banks1 accounts for such exchange as may be paid- 941 586 - i A M E M O R A N D U M TO THE GOVERNORS OF THE FEDERAL RESERVE BANKS by F. A. Delano. W ashington,. A p r il 7, 1916. A ge n e ral statement of the reasons why the time has ccrae fo r the F e d e ra l Reserve Board to put in to e ffe c t a check c le a r in g system which, even i f not complete to s t a r t w ith s h a l l be the foundation of a stru c tu re which may be com pleted w ith reasonable d isp a tch and which, w hile not re q u ir in g member banks to a v a i l themselves of the new f a c i l i t i e s , w i l l g iv e the p r iv ile g e to every member bank th a t w ishes to make use of them. F IR S T : I t i s very evident th at the F ederal Reserve Law, w hile not ab s o lu t e ly mandatory, or e n t ir e ly s p e c if ic in i t s requirem ents about c le a r in g , c e r t a in ly contemplates th a t the Board s h a ll e s t a b lis h a check c le a r in g and c o lle c t io n system, which s h a l l include i n i t s ad herents a l l member banks, and fu r n is h an e ffe c t iv e c o lle c t io n agency fo r checks drawn on member banks in a l l d i s t r i c t s . SECOND: The s h i f t i n g of reserves from banks in reserve and c e n tr a l re serve c i t i e s to F ederal Reserve Banks would, i n e ffe c t , deprive many banks in the country of o p p o rtu n itie s fo r check c le a r in g and c o lle c t io n which they have h eretofore enjoyed. The fram ers of the F e d e ra l Reserve Act, h av in g t h i s in mind, saw th a t they must create a machinery to per form the fu n c tio n s which correspondent banks had p re v io u s ly performed in retu rn f o r bank balances. THIRD: The criticism is made that, whereas, hanks in central reserve and reserve cities have in the past carried the reserve balances of their client banks, have paid interest on those balances, and rend ered important services in the matter of check collection and clear ing, and in other ways as well, it is strange that the Federal Re serve Banks, which pay no interest on reserve deposits, hesitate to perform this service cn the score cf expense- Hesitation to assume clearing and check collection functions is the more strange because of the fact that the strategic position of the Federal Reserve Banks is such as to make it possible for them to handle this business at a much lower cost than it can be handled under present conditions and .with present methods. The additional expense which such operations will entail to the Federal Reserve Banks has doubtless been over estimated and it may well be pointed out that as the overhead ex pense is already largely provided, the additional expense will be mainly mechanical and clerical, and therefore moderate and propor tional to the volume of the checks handledFOURTH: With each successive transfer of reserves (the complete transfer having already been made in central reserve cities and the final pay ments -as to reserve cities being due in May, 1J17, and in non-reserve cities in November, 1917), there is increase-, necessity and demand for a complete and satisfactory clearing system. ip./ % f? 536 - 3 FIFTH; In discussing the clearing system, reference has been made frequently to various evils in banking practice which have grown up in the past fifty or more years; for example, the common prac tice by banks in central reserve and reserve cities allowing im mediate credit and deferred debit on country bank items; or the practice whereby exchange charges are assessed against the depos itor or indorser of the check, rather than the drawer or maker. These and other practices which might be mentioned, all more or less vicious in character, should be corrected, and doubtless will be corrected or modified in future years; but it certainly woul^ be unwise to undertake too many reforms simultaneously or impose upon any proposed check clearing plan the burden of all the de sirable reforms. Doubtless we can check some of these evil practices now, can reduce "float" by more direct routing of items, and build up a machine which will be able gradually to effect other reforms, but we must not attempt to do it all at onco. SIXTH; An important feature in the development of American banking in the last two generations has been the development of book credits in the form of deposits, rather than note issues. European baulks, and especially those of continental Europe., give credit tc a borrower in the form of bank notes. In the United States the extension of credits, has taken the form chiefly of book ere fits. The immense system of 526 - i . 4 - State banks and trust companies which has developed so phenominally in late years has long been denied note issuing powers, and even the national banks use the note issuing power tc only a relatively small extent. Hence, it is a mistake to assume that the chief function of the Federal Reserve Banks is to be that of note issuing. On the con trary, it is but fair to expect that as the years roll by their more important functions will be the extension of book credits to their members and currency only In crop moving seasons or in times of stress. But member banks will net go to the Federal Reserve Balks for book credits or balances in excess of legal minimums unless these balances can be ci some service to them. If there is no check clearing system - if there is no system by which they can issue drafts drawn on Federal Reserve Banks, or send them to their cor respondents, they will not cars to avail themselves of these credits. This character of service m i l bring the member banks and the Reserve Banks in daily contact, whereas, the note issuing feature vail only bring that contact at rare intervals. Hence, it may be fairly said that the success and development of the Federal Reserve System depends quite as much an a good system of check clearing as on any other single feature. 4/7/15. O/J m3L5 586 - j. P L A II HO. 1 0 . A CLEARING AND COLLECTION PLAN Being an Evolution of the plan aubmitted by Mr. Lyman H. Talley (Proposed by Mr. 1,1. 1. Fleming., Assistant Cashier, Federal Reserve Bank of Cleveland, under date of April 7, 1916) For the utmost possible development of the check as a medium of exchange, it is obviously essential to cure the serious evils which have grown into the present methods of check collection. Four pur poses must be sought: 1: Minimize the life of the check; 2: Minimise the volume of "float” carried by the banks, especially that large part which is now fallaciously and dangerously counted as reserves; 3: Minimize the cost of collection, and eliminate exchange charges; 4: Place the cost of the service where it belongs. The plan of deferring debits and credits by schedules will shorten the life of the average chock, and will greatly reduce the float, byt will leave a, considerable volume of float to be carried by the Federal Reserve Banks. Its principal objection, however, is that it would be a radical reform, strange and novel, necessarily compulsory, and therefore unwelcome, and so it might drive member banks out of the system. It will be acknowledged that the application of the clearing house principle would be the ideal solution cf the problem if it is practicable and that clearing house operations could accomplish all Q/'ifR %U} '■ 586 - 2 - the purposes above named. ]• The Act recognises the clearing house principle in terns; and a country-wide clearing house being obvi ously impracticable provides that the Federal Reserve Board "may require each Federal reserve bank to exercise the functions of a Clearing House for its member banks." The plan herein proposed is an evolution of the "Reserve City Clearing House" as now operated in the Dallas district. all of. thfe "Outline of Fundamental Principles" Practically submitted by Governor Van Zandt is applicable tc this plan which therefore has the merits so well urged therein for Mr. Talley's plan; so it is unnecessary to re peat herein the fundamental principles of that plan, which are (without leave) "hereby made a part of this report." The features now proposed to supplement or modify the Talley Plan are a3 follows: 1. All Clearing House membership being essentially voluntary, member banks should be given the option of joining the Federal Reserve Bank Clearing Houses or accepting deferred credit and debit. 2. The Clearing House Departments of Federal Reserve Banks should be entirely independent of the Reserve Banks themselves; that is, the reserve accounts of member banks should be kept- entirely dis tinct from the Clearing House accounts. Credit, balances in the Clearing House when collected from debtor banks should however be deposited to the credit of the member bank la reserve account in the Federal Reserve Bank. Debtor banks should settle for debit balances by drafts on the Federal Reserve Ban> to the order of the Clearing House department or manager, ah provided in the Talley Plan. 586 - 3 A debtor bank obliged to ship currency tc meet its settlement draft should be credited with the actual minimum cost of such ship ment, as in the Dallas system; but it is believed that such cost should be charged to the general operating expense, rather than to attempt to charge it against the banks clearing itoms on the ship ping bank, which would involve much clerical work. 3: Each 'Federal Reserve District should be divided into a suitable number of sub-districts for clearing house purposes only; each such sub-district to contain a Clearing House Agency of the Fed eral Reserve Bank. Each such Clearing House Agency should be a member cf each other Clearing House Agency in the sam® Federal Reserve Dis trict* Each member bank should send all itarns on other member banks located within its oub-distriat to the Clearing House Agency thereof, and should send all items on member banks of other sub-districts within the same Federal Reserve District, direct to the Clearing House Agency of the sub-district in which the payer bank is located, with a du plicate letter to its own Clearing House Agency. This Agency being a member of all other Clearing House Agencies in the Federal Reserve District, receives credit on the clearing sheet of the payer bank’s Clearing House Agency, and its balances will be offset in the same manner as balances between other members of that Clearing House Agency. All balances, however, should bo settled on the books of the Central Clearing House at the Federal Reserve Bank; and there the offsets will probably be -such as to coviaio the necessity of appor tioning credits as in the Talley Flan. Resultant balances between j. 948 - 4 - 586 - the several agencies would also he settled through the Central Clearing House Department at the Federal Reserve Bank. 4: Items of non-member banks may be cleared through member banks, as is now the custom in some, local Clearing Houses* For the service of clearing or collecting items presented by member banks, but bear ing the indorsement of non-member banks, an additional discriminatory charge should be made. .INTER-DISTRICT OPERATIONS 5: The handling of checks payable outside of the Federal Re serve District of the depositing bank, although involving deferred settlements, can be conducted in a similar manner. Member banks having items payable outside of their own Federal Reserve District could send all such items direct to the Clearing House Department of the Federal Reserve Bank of the district in which the payer bank is located, or to its sub-district Clearing House Agency; or to the payer bank direct if located in a center, but in each case for credit of the Clearing House Department of their own Federal Reserve Bank; at the same time sending duplicates of such letters to the Clearing House Department of their own Federal Reserve Bank. The payer bank’s Federal Reserve Bank will then advise the depositing bank’s Federal Reserve Bank. A bank having a small number of items pay able in other Federal Reserve Districts might be permitted to send all such items to its own Federal Reserve Bank for sorting and trans mission, although each member bank should be urged to send items j. r5- { 949 -586 - j- direct to the district where payable whenever possible to avoid delay in transit- Resultant debit or credit balances in the Inter-district system should be settled in the same manner as those in the Intra district Clearing House with the exception that they would be cleared through the Gold Settlement Fund. EXPENSE OF OPERATION. 6: The expense of maintenance and operation may be provided for as suggested in the Talley Plan as far as Intra-district clear ings.are concerned. In Inter-district operations a Federal Reserve Bank Clearing House receiving items from banks in other Federal Re serve districts direct should not enter any item charges upon its books, but the Federal Reserve Bank of the District where such items originate should make an item charge from the duplicate letter of advice received by it from its member bank which has sent the items to the other Federal Reserve District. The item charge for both Intra and Inter-district items should, of course, be sufficient to cover all incidental ex penses, including any necessary remittances of funds. U/7/lS 950 586 - k. PLAN II 0 . 1 1 ■ FEDERAL RESERVE BARK OF ST. LOUIS. PLAN FOR THE COLLECTION OF CHECKS IS INTENDED TO SHOW: THE FOLLOWING WHAT WE BELIEVE SHOULD BE DONE; THE REASONS WHY WE BELIEVE SC; AND THE METHODS PROPOSED TO ACCOMPLISH IT. FUNDAMENTALS: REASONS: METHODS: 1 - All member banks should receive at par checks drawn on them, which have been deposited in the Federal Reserve Banks. This should be mandatory. This is based upon the last two para graphs in Sec. 16 of the Federal Re serve Act. It should be put in to effect by orders issued by the Fed eral Reserve Board. 2 - The Inter-Dis trict exchange of checks should be put into,effect simulta neously with the man datory collection of checks on members. Any practical method of collecting checks must include means for the passing of a check from the Dis trict where it is negotiated to the District where it is payable. Federal Reserve Banks shall receive for credit from other Federal Reserve Banks checks drawn on points in the form er Banks' Districts Further details are given under Sec; 6 . 3 - Federal Reserve Banks should receive from Member Banks, and other Federal Re serve Banks checks drawn on Non-member banks, on the basis of the exchange cost on such checks. Recognition must be given to con ditions actually existing. The National Banks are now handling 75$; to 80$ of the country checks in circulation, consisting of checks on Members and on Non-member banks. The checks on Members will be turned into the Federal Reserve Banks, who will therefore accumulate 75 to 80)6 of the checks drawn on their members; and the members will have to provide payment for them to the Federal Re serve Banks. Some assistance should be given to the Country Member to restore its reserve balances thus depleted by the Federal Reserve Bank. i A start can be made by collecting checks on non-members lo cated in the same place as a member at par if possible, at a slight service cost if necessary. The Federal Reserve Bank will then begin negotiations with non-members located in places where there are no members for the collection of checks on such o f-i-f - 2 FUNDAMENTALS-: REASONS: 3 - (Continued) Owing to the greater number of State Banks, the outside chocks received by a country member are mostly drawn on State Banks in the- vicinity. Some are drawn on National Banks, which can of course be sent to the Federal Reserve Bank, but these do not by any means provide a fair offset to the payments the country member has to make to the Federal Reserve Bank. To say to the country member bank that it can restore its depleted balance by sending a check on its City cor respondent is to say: "We leave you whore we found you, and you must find the means to offset a situation cre ated by the Federal Reserve Bank." The equitable way is for the Federal Reserve Bank to provide the member bank with the means to convert all of its outside checks into a credit balance in the Federal Reserve Bank, at a minimum expense to all concerned. The collection of country checks will not in practice prove to be such a tremendous country-wide affair as first appears. The outside checks received by a country bank are largely drawn on banks in its vicinity and by far the larger part of them would not go outside of the Reserve District in which Vie Member is lo cated if the Federal Reserve Bank undertakes their collection, ai.d declines to receive from another Federal Reserve Bank checks already endorsed by a bank located in the district of the receiving Federal Reserve Bank. The collec tion of country checks will resolve itself into a local proposition. 4 - The Federal Re serve Banks should differentiate between Non-member banks who remit at par for checks sent thorn by Federal Reserve Banks and those who charge. Under any comprehensive plan of col lecting country checks a Non-member can receive by virtue ox a. connection with its City correspondent all of tfce' advantages of the collection fa cilities of the twelve Federal Re serve Banks. Unless some' distinc tion is drawn between the Non-member 586 - k. METHODS: banks, on as favorable terms as possible, in exchange which is con venient tc the remit ting bank and convert ible by the Federal Reserve Bank4 Since the twelve Federal Reserve Banks will be come the largest col lectors of country checks, they will se cure the lowest rates from the banks who charge exchange. They will be X+l pc3 ition to offer certain ad vantages tc non-mem bers who retait at par, as will be explained in Section 4 4 The manner of giving credit to the sending member bank for checks on Non-members will be explained further on. The differential charge shall be the same rate of exchange which is charged by the endorsing bank on items sent it by the Federal Reserve Bank. The rate will be as- - 3 - FUNDAMENTALS; REASONS: 4 - (Continued) This should os a who remits at par for the Federal charge made on account Reserve Bank, and the one which will of the endorsement cf not, the latter bank receives an a Non-member tank undue advantage over the former and which does net remit al30 over Member Banks. A 'way at par for the Fed should oe found to equalize this eral Reserve Bank.The discrimination and offset the un due advantage given the Ion-member enforcement of the who seeks to enjoy the facilities differential charge will be voluntary on cf the federal Reserve Banks and make a profit from them at ens and the part of the the same time. It is proposed drawee bank, as ex that the Federal Reserve Bank plained in the reason for levying the charge charge exchange cn any check, which reaches it, that io endorsed,by a Mon-Bomber who charges for remit ting to the Federal Reserve Bank. This differential charge shall be at the same rate ci exchange as the Non-member charges the Federal Reservo Bank. The exact amount of this charge is to be paid to the Bank cn which the check is drawn, if the drawee bank remits at par for checks sent it by the Federal Reserve Bank. It is apparent that the Federal Reserve Banks can by this means have a definite ad vantage tc hold out ic the bank who will remit to it at par. It is true Member banks have been urged to join the clearing system, mow in use on the ground that they can have their customers' checks collected at par through the Fed eral Reserve Bank. This differ ential charge will effect this to a certain extent; but it will re turn the Member Bank the exact amount of the charge levied on its cue tome rc* checks, putting it in position to return it to the cus tomer; OR,IF DESIRED BY THE MEMBER BANK, nc differential will be im posed on its customers' checks on account of endorsemert, if it pre fers this to being paid exchange on them. 586 - k. METHODS: certained from the negotiations to be carried cn as ex plained under Sec.3. The charge is to be levied against the depositing member bank. The chatge is to be levied by the Federal Reserve Bank in which the item is first de posited. The Fed eral Reserve Bank of the District will know what banks in its District are charging exchange. It is apparent that the bulk of the out side items endorsed by these charge-banks will be offered to the Federal Reserve Bank located in it3 District. (See last paragraph in "Raisons" Sec. 3). The amount of the charge will be noted on the letter of transmittal carry ing the item, from the Federal Reserve Bank tc the Member Bank or another Federal Reserve Bank. The check charged on will be indicated by a symbol opposite the check. A coupon at the foot of the letter will name the amount cf the check on which the’i n f e r ential has been levied, amount ox the charge and contain a request to deduct - 4 FUNDAMENTALS: 4 - (Continued) REASONS: The bulk of the exchange charges on checks is levied by country banks in the smaller towns and cities. It is no secret that the evil of exorbitant exchange charges is rooted in the competition of reserve city banks for accounts of country banks. Ex perience of the past twelve months has demonstrated that little assist ance can be expected from interests outside of the banks in the solution of this exchange problem. The first step towards a solution must be reached in the relations between a country bank and its reserve city correspondent. By imposing a dif ferential charge on the checks, which can be deposited in a Federal Reserve Bank, the Reserve City bank will soon have two plans which it can extend to the country bank for the handling of its items. One plan to the bank which remits at par for the Federal Reserve Bank (Whose items can be deposited through a Member at par in the Fed eral Reserve Bank) and a second plan for the bank which charges the Federal Reserve Bank and 'whose items are therefore subject to a charge if deposited in the Federal Reserve Bank. The profits to the reserve city bank will be quite different on the first class from the profits on the second class of accounts. This wide difference in profits will soon effect the basis upon which the reserve city bank can receive the country account. Country banks will, by their own volition, divide themselves into two classes. Those banks, having a large volume of outside checks to collect, will manifestly find it to their interest to par for the Federal Reserve Bank, while those having only a small volume of out- 586 - k. METHODS: the amount of it from next remittance, if the check is drawn on a non-member who pars; or if drawn on a member the cou pon will be an ad vice o£ credit. If the letter of trans mittal is to another Federal Reserve Bank, the notation will be an advice of credit for the knount of the differential.If the check is drawn on a Non-member who charges the Federal Reserve Bank, the amount of the dif ferential will be retained by the Fed eral Reserve Bank, and used to reduce the cost of check collection. Member banks will be furnished with a list of the banks who charge the Fed eral Reserve Bank, so that they can arrange accordingly for handling items with charge bank endorsements. Federal Reserve Banks will not receive from other Federal Re serve Banks items bearing the endorse ment of member or non-member banks, lo cated in the second Federal Reserve Banks' District. All Fed eral Reserve Banks 954 - 5 FUNDAMENTALS ♦ 4 - (Continued) REASONS: 586 k. METHODS: •side checks may prefer to charge tne |Federal Reserve Bank and pay the |same rate on the outside items £t may receive from its customers. 'Eventually the number of banks icharging exchange will be reduced !to a minimum . will exchange with each other lists show ing rates of exchange paid to the various non-member banks. 5 - The twelve Federal; This is following long osteblishod Reserve Districts |lines of practice in the collection should be sub-divided ;of country checks. The commercial and Sub-Agencios os- ibanks of tho country have found it tablished for the col-jnecessary to distribute country ion of checks in checks through 50 to 60 centers* the immediate v ic in it y ! Experience has developed tho neces o f the Sub-Agency. sity for thi3. The Sub-Agencies The d is t r ib u t io n o f ! should be so located that a majority Sub-Agencie's should j of the banking towns in the subbe so arranged th a t district are within one day's time the m a jo rity of bank from the Sub-Agency. This will en in g p o in ts in the able a remittance containing checks Reserve D i s t r i c t are on members to be credited the next w it h in one day’ s time business day after receipt at the from a Sub-Agency. Sub-Agency, and enable remittances of checks on Non-members to bs credited two days after receipt at the Sub-Agency. The principal ar gument advanced against the parring of checks has been the coat to the paying banks to make the exchange in which it is required to remit. If Sub-Agencies are properly lo cated, banks remitting to them will remit in exchange which they make readily and which costs nothing. Location of Sub* Agencies shall be designated by the Fed eral Reservo Bank. Tho Sub-Agencies may bs Member Banks, but the men handling the items should be em ployes of the Federal Reserve Bank, under proper bond. A list of Sub-Agencies shall be furnished member banks in the district with instructions to send items in the SubDistrict to the SubAgency. Receipts at each Sub-Agency may be telegraphed if necessary to the Fed eral Reserve Bank, and confirmed by mail. The manner of entry on the books of the Member Bank of remit tances sent to the Sub-Agency is taken up further on. 6 - Checks on Member It is the purpose of this method to Banks or Federal Re enable X Bank to realize on a check serve Banks should be drawn on Y Bank within the same credited to tho send period that Y Bank can realize on ing bank on the day a check drawn on X Bank. It is in the checks should tended that a check drawn on a Mem roach the drawee bank. ber Bank shall become reserve for the sending bank on the day the Checks on Non-Member check reaches the drawee bank. The banks should be lending bank will accordingly charge credited on the day !the Federal Reserve Bank with re returns for same should reach the Fed- mittances sent it on the day such Member Banks will be furnished with forms of remittance letters which will show that the letter is ad dressed to a SubAgency, the Federal Reserve Bank of its district, or a Fed eral Reserve Bank or Sub-Agency outside of it3 District. f FUNDAMENTALS: 6 - 6 t* REASONS: 586 - k. - METHODS: (C on tin ued) era! Reserve Bank collecting same. remittances should, reach the drawee hanks. Its hooks will therefore correspond with the hooks of the Federal Reserve Bank . ■What is visually termed in transit ; matters "the float" is the volume of checks which have been credited to depositors* accounts and are in process of collection. It grows out of the long established practice of giving credit on receipt to a de positor of checks on outside points. Manifestly the crediting hank re ceives some advantage in this manner of handling outside items. It is also plain that the drawee hank re ceives some advantage from the cir culation of its customers checks drawn on it. The above plan divides the burden of this "float" equally between the reoaiving bank and the drawee bank. It is proposed as being an equitable division. It is based on the belief that a Federal Reserve Bank can define when a Member Bank may count as reserve any checks de posited in the Federal Reserve Bank. The form will show when the Member Bank is tc charge the re mittance to the Fed eral Reserve Bank. It may charge checks on the same city in which.a Sub-Agency of Federal Reserve Bank is located to its reserve account one day after trans mittal . Checkfe on other members in the District shall be charged two days af ter transmittal; Checks on Non-Members in the District may be charged three days after transmit tal. This will take Care of the bulk of the outside checks re ceived by the aver age country member. Shere will remain a small volume of checks cn points outside of the Dis trict, which may be sent to the Federal Reserve Bank of the member’s district or by arrangement to a Federal Reserve Bank located in the district where the checks are payable. It will not be dif ficult to arrange with the large col lecting banks a practical convenient method for the hand ling of chacks on points outside of their Vein— Pare- — 7 FUNDAMENTALS: 6 - (Continued) REASONS: 586 - k METHODS a matter which must be left to the dis cretion of the Federal Reserve Bank concerned. Remittances containing checks on non-members shall be separated from those containing only checks on Members. The exchange charges if any on checks on Non-Members will be assessed the deposit* ing bank on receipt of the check, if with in the District. If the check is drawn on a point Outside of the district, the ex change will ba as sessed on receipt of advice of the col lecting Federal Re serve Bank. Exchange charges on non-member checks received from other Federal Reserve Baucks will be assessed on receipt of the check, from the known sche dules of charges which the Federal Reserve Bank will have on file from non-members in its District. Lists showing time in transit will be fur nished Members and Federal Reserve Banks. It is recommended that the question be taken up later for adjustment, ae to when drafts drawn by a member bank on its Federal Reserve Bank shall be deducted from the drawers bal ance on its books. si - 8 - FUNDAMENTALS: 7 - Currency or coin shipments made by a Member to a Federal Reserve Bank shall be at the expense of the shipping bank, but shall be counted as reaerve on the date the shipment is made by the Member Bank. 8 - Checks represent ing transfers of fur.cfe shall be received on a basis to be fixed by the Federal Reserve Bank concerned. 5 - Reserves of Mem ber Banks shill be computed from the books of the Federal Reserve Bank. 10 - Settlements be tween the Federal Re serve Banks in the Gold Fund should con tinue as heretofore until experience de velops the necessity for more frequent REASONS: jThe establishment of Sub-Agancies will largely offset the need for icurrency shipments for purposes of |making exchange. They will thereifore be made principally as a mat!ter of convenience to the shipping jbank. They should be counted as re serve while in transit, 3 ince the currency would probably be reserve, had it remained in the pember's vault, This is to permit Federal Reserve Banks to engage in the purchase or sale of domestic exchange in ac cordance with conditions existing at the time of the transaction. 536 - k. METHODS: No details are needed. The shipments will simply be counted and credited on receipt. The manner of entry of such transfer checks is to be left to the discretion of the Federal Reserve Bank concerned. By direction of the The carrying out of Section 6 will enable the Member Banks to have their Federal Reserve books agree with the Federal Reserve Board Member Banks shall make a period Bank. The equitable division of ical report of their the burden of uncollected checks is jexplained in the same Section; as is j re serve re quirenent s. jalso set out the jurisdiction cf the A comparison wall then be available with [Bank in the calculation of reserves the reserves actually jcarried with it. 'carried. If any pen-, alty be necessary on account of deficiency maintained over a given period it can then be fined as may be directed by the Federal Reserve Board as provided in Sec tion 15 of the Act. The present method to continue' until, ex perience develops the necessity for change. This recommendation carries its own reason. The present -method to continue until ex perience develops the Inecessity for change. - 9 - FUNDAMENTALS REASONS: 11 - That unifora me theis should he followed “by Federal Reserve Banks in the handling of InterDistrict remittances. Federal Reserve Banks should be en abled to have their books agree with every other Federal Reserve Bank at the close of business each day. 1Z - The expense of operation should be left as a matter to be taken up later after experience has developed the approx inate cost psritem. After a few months1 operation, some definite figures will be obtained and from then cn an equitable assess ment of expense can be levied. 4/10/16. 5 S6 - 3c. METHODS: Uniform types of re mittance letters should be adopted, showing when each re mittance will be charged by the send ing bank. Advices of credit by the receiving bank should show when the out- ' side checks will be available for the sending bank. They should be held in a Transit account un til the date the funds become avail able « l ^ <Q KJ? i.'7 W. P. 0. HARDING, GOVKRNOR PAUL M. WARBURG. VlCI GOVERNOR FREDERIC A. DELANO ADOLPH C. MILLER CHARLES S. HAMLIN Kx-Officio Member* WILLIAM « . MCADOO SECRETARY OF THK TREA8URY CHAIRMAN JOHN SKELTON WILLIAMS H. PARKER WILLIS. SECRETARY SHERMAN P. ALLEN. Af ST. SECRETARY FEDERAL RESERVE BOARD COMPTROLLER OF T N I CSRHNNCT and Fiscal as e n t ADDRESS REPLY ® g 7 # WASHINGTON FEDERAL RESERVE BOARD March 1916 . Dear Sir: The following message was authorized by the Federal Reserve Board at its meeting of March 2 1 , and was 3ent to all those banks, which have filed applications for the sale of bonds, vdiich could not be reached in sufficient time by mail. "Applications for the sale of bonds through the Treasurer of the United States on March thirty-first have been received from member banks up to the closS of business today. Indications are that bonds offered for sale will very considerably exceed'amount to be al lotted to Federal reserve banks because many of these banks have already purchased more than their allotment. Hence in answer to an inquiry the Board has ruled that applications may be withdrawn if request for withdrawal is received by the Board before March twenty-eighth." The notice is mailed to you as an applicant bank and reply may be sent by mail or telegraph in the event that you *\ desire to withdraw all or any of the bonds you have tendered. The notice must, however, be received by the Board before the close of business on March 2Sth. Respectfully, Secretary W. P. G. HARDING, G O V E R N O R WARBURG, V ic e g o v e r n o r a A. DELANO C. MILLER CHARLES S. HAMLIN Ex -O fficio Members WILLIAM G. McADOO SECRETAR Y OF THE TREASURY C h a ir m a n . JOHN SKELTON WILLIAMS H. PARKER WILLIS. S E C R E T A R Y SHERMAN P. ALLEN, A S S T . S E C R E T A R Y FEDERAL RESERVE BOARD Co m p t r o l l e r o f t h e c u r r e n c y and WASHINGTON Fis c a l A g e n t A D D R E S S R E P L Y TO FEDERAL RESERVE BOARD / March 2U, 1916 Sir In answer to several inquiries regarding proper entries to be made on Forms 3X and FRA-5, in case of redemption of Federal reserve notes., either, "fit" or "unfit",' received from a Federal reserve■bank, a Federal reserve agent, or in the ordinary course of business, the. following entries are suggested as satisfactorily representing the transactions in question: 1. When cancelled Federal reserve notes are forwarded by the bank to the Treasurer of the United States for re demption, the bank should increase on Form 3 ^ "Mutilated currency forwarded for redemption11 (Item BONE) and decrease "Federal reserve notes on hand1’ (Item BEET); no entries,, however to be made on FRA-5* (a) When advice is had from the Treasurer of the United States to the effect that such notes have been received (notices being sent simultaneously to the bank and the Agent),, the bank should increase either "Gold settlement fund" (BABE) or "Gold redemption fund" (BELT); depending on what arrangement is made between the Agent and the bank and with the Treasurer ox the United States, 961 - 2 - 583- and sh ou ld decrease a t the same time "M u tila te d currenoy forwarded fo r redem ption" (BONE). (b) In case g o ld or la w fu l money i s returned to the “bank by the Agent on account of F ederal reserve notes re deemed, the b a n k 's cash reserve (g o ld or la w fu l money) should be increased in ste a d of the items s p e c ifie d in paragraph ( a ). In the memorandum account on the l i a b i l i t y sid e of Form the fo llo w in g chsuiges should a ls o be made: Decrease "F ederal reserve notes o u tsta n d in g " (Item DEER); a ls o "G old and la w fu l money" (Ite m DOPE). T h is w i l l r e s u lt in reducing the amount of Fed* e r a l reserve notes o u tsta n d in g a3 w e ll as the amount of g o ld or la w fu l money deposited w ith the Federal reserve agent, but w i l l leave the bank'3 net l i a b i l i t y on F ederal reserve notes o u tsta n d in g unchanged. Upon re c e ip t of n o tic e from the Treasu rer of the U nited S t a te s , the Agent should in crea se on Fora: FRA-5 j "Fe d e ra l reserve notes returned to C o m p troller of Currency fo r d e str u c tio n " and should decrease "F e d e ra l reserve notes o u tsta n d in g ", "P r e v is io n fo r redemption of F e d e ral reserve n o te s", and "C re d it balance in go ld redemption fu n d ", except when go ld or la w fu l money i s returned by the Agent to the bank, in which case "Gold on hand" or "Law ful money on hand" sh ou ld be decreased in ste a d of "C re d it balance in g o ld r e - 962 - demption fu n d ". 3 5S9« - Whenever a t r a n s fe r of c r e d it s i s made from the A g e n t's c r e d it "balance w ith the F ederal Reserve Board to the b a n k 's account in the g o ld settlem ent fund in connection w ith the redemption of F ederal reserve notes, a p p ro p riate e n tr ie s should be made on Form FRA-5* II. When n o tic e i s had by the F ederal reserve agent from the Treasurer of the U nited S ta te s th a t " u n f i t " F ederal reserve n otes, received from some source other than the bank, have been redeemed by him and charged to the A g e n t's g o ld redemption fund, the fo llo w in g changes should be made on Forms 3*+ and FRA-51 In the memorandum account on the l i a b i l i t y sid e of Form the bank should decrease "F e d e ra l reserve jiotes o u t s ta n d in g "( Item DEER) and"Gold and la w fu l money w ith Fed e r a l reserve agent for* the retirem ent of o u tsta n d in g Federal reserve n o te s " (Item DOPE). T h is w i l l r e s u lt in red ucing the amount of each of these two item s, but w i l l leave the b a n k 's net l i a b i l i t y on F ederal reserve notes o u tsta n d in g unchanged. The F ederal reserve agent should in crease on Form FRA-5 "F e d e ra l reserve notes returned to C o m p trolle r of Cur rency fo r d e s tr u c tio n " and should decrease "F e d e ra l reserve notes o u tsta n d in g ", "C re d it balance in g o ld redemption fund", and "P r o v is io n fo r redemption of F e d e ral reserve n o t e s ". 963 _ k - III. 5S9- In case "fit" Federal reserve notes are redeemed by the Treasurer of the United States., they will be charged to the bank's gold redemption fund and returned to the bank of issue, in which case the Federal reserve bank should increase "Federal reserve notes on hand" (Item BEET) and decrease "Due from Treasurer of United States, gold redemption fund" (item BELT). . No entries should be made by the Agent on Form FRA-5IV. When cancelled Federal reserve notes are returned by the Agent to the Comptroller of the Currency for destruc tion, the Agent should increase "Federal reserve notes re turned to Comptroller of Currency for destruction" and de crease "Federal reserve notes on hand". be made by the bank on Form No entries should 3 ^* Where.reference is made to changes on Form it is understood, of course, that appropriate entries shall be made in general ledger accounts, balances of which only are shown on Form 3^* It is thought that the above suggestions, while by no means exhaustive of the subject, will be found sufficiently de tailed to insure uniformity of treatment by all Federal reserve banks of all the various transactions connected ’with the redemption and destruction of Federal reserve notes. 964 - 5 - 589- The appended chart, prepared by Mr. H. M. Jefferson of the Federal Reserve Bank of He^v York, may be found useful in this connection. Respectfully, Governor. 965 % W. P. G. HARDING. GOVERNOR PAUL M. WARBURG, VICE GOVERNOR FREDERIC A. DELANO ADOLPH C. MILLER CHARLES S. HAMLIN EX*OPFlCIO M E M B E R * WILLIAM 0 . MCADOO SECRETARY OP THK TREASURY CHAIRMAN JOHN SKELTON WILLIAMS COMPTROLLER O P T M I CU RRENCY FEDERAL RESERVE BOARD WASHINGTON H. PARKER WILLIS, SECRETARY SHERMAN P. ALLEN* ARET. SECRETARY and Fis c a l FEDERAL RESERVE BOARD March 27, 1916. Dear Sirs: . One of the hanks in your section of the Federal Reserve District of Dallas has written to the Federal Re serve Board stating its desire to he transferred to the Fed eral Reserve District of Kansas City, urging as the reasons for such transfer; geographical location, better mail facili ties, and the necessity for carrying balances in Kansas City, Will you please advise me whether you are satisfied to remain attached to the Federal Reserve Bank of Dallas or if you would prefer to be transferred, if this can be done? Very truly yours. « A DDRE SS r e p l y t o 966 W. P. 0 . HARDING, GOVERNOR PAUL M. WARBURG. VICE GOVERNOR FREDERIC A. DELANO ADOLPH C. MILLER CHARLES S. HAMLIN WILLIAM « . McADOO SECRETARY OF T H I TREASURY CHAIRMAN JOHN SKELTON WILLIAMS COMPTROLLER OF THE CURRENCY FEDERAL RESERVE BOARD H. PARKER WILLIS. SECRETARY SHERMAN P. ALLEN. ASST.SECRETARY AND FISCAL AOENT ADOI WASHINGTON TO FEDERAL RESERVE s e r v k BOARD 5y* March SB, 1916 Dear Sir»i There is enclosed for your information copy of a resolution, adopted by the Federal Reserve Board at its meeting today, in connection with the sale of United States bonds offered by member banks of the Federal reserve system through the Treasurer of the United States under Section IS of the Federal Reserve Act* You will note from the resolution that the Board has determined under the circumstances to make no allotment Of bonds for purchase at this time* Very respectfully, Governor RESOLUTION ADOPTED BY THE FEDERAL RESERVE BOARD Tuesday, March 2S, I91S. W H E R E A S , It appears from statement furnished the Board "by the office of the Secretary that eleven out of the twelve Federal reserve hanks have purchased in the open market bonds in excess of the amount which might he allotted to such hanks at the end of this quarterly per iod on a basis of one-fourth of twenty-five million dol lars which the Board had considered alloting at this time, and W H E R E A S , The bonds offered for sale through the Treasurer under Section IS of the Federal Reserve Act aggregate more than twenty times the amount which might he allotted on the basis indicated, and it will, there fore, be possible on this basis to sell for each member bank less than five per cent of the amount offered for sale, and W H E R E A S , It appears that the only Federal reserve bank which has not purchased in the open market bonds in excess of the amount which might be allotted to it is under contract to purchase a sum very largely in excess of its allotment and has been prevented from con summating such purchase by reason of the fact that more than nine million dollars in lawful money has been de posited with the Treasurer during the current month to retire circulation by national banks and the banks under contract to sell are thereby prevented from making de livery. NOW, THEREFORE, BE IT RESOLVED, That it is the sense of the Board that no necessity exists for enforc ing the requirement provided for under' Section IS of the Federal Reserve Act at the end of this quarterly period ending March 3 1 # 19l6 , and that it will not at this time require the Federal reserve banks to purchase any of those bonds which are-offered for sale by member banks through the Treasurer of the United States under the provisions of Section IS. BE IT FURTHER RESOLVED, That the Secretary be in structed to send a copy of this resolution to the various Federal reserve banks and to the member banks which have offered bonds for sale in order that they may be notified of the action of the Board in the premises. THE PRESENT COTTON SITUATION. SPEECH OP W. P. G, HARDING, MEMBER FEDERAL RESERVE BOARD, UNDER THE, AUSPICES OF THE BIRMINGHAM CHAMBER OF COMMERCE, AT BIRMINGHAM, ALABAMA* FRIDAY EVENING, MARCH TENTH, 1916. (For release Saturday morning, March 11) During the next six weeks, assuming normal weather con ditions, the cotton crop of 1916 will he planted. While the acreage put in cotton will hear a direct relation to the size of the new crop, other factors must he considered in reaching conclusions as to the final outcome. The quality and amount of fertilizer used, the character of the season, methods of cultivation, the ravages of the hell weevil and other insect damage will all have an important hearing, so that under some conditions it is conceivable that thirty million acres planted in cotton will produce a larger yield than thirty-five million acres under other conditions. The new crop acreage however, which will probably he known definitely within the next sixty days, will play an import ant part in fixing the market value of that portion of the crop of 1915 which remains unsold, for it is likely that not until July will reports of condition of the growing crop become a factor in price control. It will he remembered 9 ~z~ that during last July there was a decided slump in the cotton market which brought about an extremely nervous feeling throughout the South. Despite the very vigorous and dili gent campaign that had been made in the spring of 1915 for a sharp reduction in cotton acreage, reinforced as it was by the severe object less*a of the dangers of over-production that had been impressed upon cotton growers during the preced ing Fall and Winter, it was found that the area planted in cotton had been reduced by only about 15$. The season up to July had been propitious and there was much talk of a new crop of at least fourteen million bales. It was known also that. Great Britain intended to declare cotton an absolute contraband, which was regarded as meaning the loss of a mark et for about two and one-hglf million bales which had usually gone to Germany and Austria, and which had, to a considerable extent during the season of 1914-1915, reached those countries through neutral ports. Farmers and business men throughout the South were aroused, and, without any definite organization, but through the force of public sentiment, a policy of gradual marketing was decided upon. Warehouse facilities had been found to be adequate and the banking situation was such as to render ample funds available to carry out such a policy. At the same time it became evident 970 -3- that the yield would not he as large as had been anticipated, so that consumers, finding that there be no rush of cotton to the market, for sale at forced prices, began to contract for their wants, and prices advanced rapidly. The new crop, in stead of bringing seven to eight cents per pound, as had been predicted by many pessimistic persons, found a ready market up to 12g-/ per pound, and cotton seed advanced in a corres ponding degree so as to give producers the equivalent of $20.00 to *22.50 per bale from sales of seed. The advance attracted speculative interest and by December some enthusiasts had visions of 15 to 18 cents per pound. Many farmers and merchants who, a few weeks before would have sold most gladly at 12 cents, caught the infection and decided to hold for the much higher prices which they felt were coming. About this time however, the export movement began to compare unfavorably with the previous season. Ex:cept as to coastwise trade, our ocean freights are carried almost entirely in foreign bottoms. Of these, German vessels are idle, being interned in neutfsp. ports throughout the world, of the North Sea. or else blockaded in the waters This scarcity of shipping has caused a great advance in ocean freight rates, which are from six to ten times the normal, so that rates on cotton from American ports to Liverpool have been ruling as high as three dollars per hundred pounds, or fifteen dollars per bale, being three cents per pound* Even at these abnormal rates, exports of cotton have been restricted, as ship owners, acting probably under instructions from their Governments, have given prefer ence to cargoes of grain and munitions. stocks abroad have been greatly reduced, Under these condition and during the month of January there was a time when the stock at Liverpool was sufficient to supply British spindles for less than six weeks, with prices ruling at 18/, against 12/ in Hew York. There is reason to believe however, that during’the past month arrangements have been made to increase the ship room available for cotton, and there has been some increase in the supply at Liverpool, London and Manchester. The total stocks in Great Britain on March 3rd have been estimated to be 1,000,000 bales, against 1,452,000, 1,209,000 and 1,498,000 bales for the same date in 1915, 1914 and 1913, respectively. The depletion of stocks on the Continent is still more marked. The Financial Chronicle estimates the supply of stock at Ham burg, Bremen and Trieste to be about 1,000 bales at each point, against a total of 384,000 bales on March 1st, 1315, 570.000 bales in 1914, and 578,000 bales in 1913; cluding stocks at Havre, Marseilles, and, in Barcelona and Genoa, it estimates Continental stocks on March 3rd at 479,000 bales, against 1,083,000 bales in March 1915, 1,065,000 in 1914 and 1.089.000 in 1913. The Chronicle places the total visible - 5- supply for the world on March 3rd at 5,777,448 bales, against 7,607,227, 6,107,140, and 5,491,952 bales in 1915, 1914 and 1913, respectively. In Egypt figures relating to cotton re ceipts are expressed in cantars, approximating 100 pounds, and exports in bales which weigh about 750 pounds. Reducing the figures to the equivalent of 500 pounds to the bale, receipts of cotton at Alexandria from August 1st to February 9th have been, according to the same authority, 790,300 bales against 042,500 bales last year, and 1,350,000 bales for the same date in 1914. The Financial Chronicle's report dated Friday night, March 3rd, gives the following statement as to the movement of the crop for the week: Total receipts, 107,849 bales, against 156,956 and 142,403 bales for the two weeks immediately preceding. Total receipts since August 1, 1915, 5,402,039, against 8,093,162 for the same period of 1914-15. since August 1, 1915, 2,691,123 bales. 142,143 bales, Decrease Exports for the week, of which 73,972 were to Great Britain, to France, and 44,046 to the rest of the Continent. 24,125 Total exports August 1, 1915 to March 3, 1916, to Great Britain, 1,755,493 bales, against 2,487,993 bales for the same period last jTear; to France, 510,883, against 376,892; to Continent, 1,295,565, against 2,672,188, making a grand total of 3,561,941, against 5,537,073 last year, and 7,296,085 for 1913-14. export movement therefore, The is approximately 2,000,000 bales f -6- behind last year and nearly 3,750,, COO bales under 1914. There seems to be no material difference of opinion on the part of various authorities as to stocks of cotton held abroad or as to the exports, but there is some divergence in the views as to the domestic situation. A well known cotton authority, who prefers not to be quoted, gives me. the following estimate of the supply of cotton in America on July 31, 1916, at the close of the current cotton year: Visible supply in U. S., July 31, 1915.......1,300,000 Unmarketed on plantations, July 31, 1915.... 1,800,000 Crop 1915-1916 (including linters)..... ....12,250,000 Total supply this season................15,350,000 American consumption..... . .7,000,000 Total exports........... ..6,500,000 15,500,000 leaving on hand visible and invisible. . Z 1,850,000 and checks his figures as follows: Unmarketed July 31st, 1915.................... 1,800,000 Crop, 1915-16............................... .13,250,000 Total supply from plantations......... ..14, 050,000 In sight to February 26th, 1916........... .. 9, 554,795 Unmarketed supply February 26th......... 4 495,205 Stock U. S. ports, Feb. 26th................. 1 410,285 Stock Interior towns Feb. 26th............. 1 102,047 Total supply in U. S. Feb. 26th......... 7,007,537 U. S. Consumption, season....7,000,000 Total takings to Feb. 26th...4,684,000 Still to be taken.......2,316 ,'000-2316000 Exports, season 6,500,000 Exports to Feb.26th..........3,561,922 Still to be exported. ... .2,9"S8,078-2938078 5,254,078 1,753,459 I quote as follows from a letter received from him: "It is reasonably plain that if we export 6,500,000 hales of cotton this year, w e .shall not have more than about 1,800,000 hales left over in the United States. This includes the cotton at the ports and interior towns as well as the unmarketed supply on the plantations. I do not think it can be consi dered burdensome with the financial facilities that the Federal Reserve Banks provj.de, and if the war ends during the present summer, I believe that all the cotton that is left over and all that America can possibly produce next year will be required to fill up the vacuum created by the blockades and the w a r .,T Another view is given in the weekly cotton letter dated March 4th of a well known brokerage house which adopts the figures and estimates of the Watkins Bureau. From this s t at erne nt I quo t e : "The world's visible supply of American cotton is now 1,604,000 bales less than at this date last year and 64,000 less than in 1914. The stocks of American cotton in Liverpool with one exception, are the smallest in the past ten years, and prac tically the same is true of Continental stocks of American cotton. Our cotton markets are absolutely closed to Germany and Austria, which was not the case at this date last year and yet in spite of the extraordinary advance in ocean freight and in surance (the rate to Liverpool is now $15.00 a bale as compared with about $1.00 August 1, 1914) we exported the first six months of the season 2.961.000 bales and to date 3,680,001, clearly in dicating an export movement for the season of fully 6,000,000 bales. The domestic consumption for the first six months of the season amounted to 3.528.000 bales and it is increasing as the season advances, foreshadowing a total of fully 7,250,000 bales for the year. With a supply of about 14,675,000 t/ <r >■ -8- bales (made up from the carry-over from last year of 2,765,000 bales, the crop estimated' by the Government at 11,161,000 and an'estimated 1 inter crop of 750,000) and allowing 6„000,000 bales for export and 7,250,000 for domestic consumption, we would close the season with an apparent surplus of 1,425,000 bales«-,T There is a difference in the estimates of these two authori ties of 425,000 bales. The first mentioned estimate places the carry-over from last year at 3,100,000 bales, while the second puts the amount carried over at 2,765,000 bales. The first places the present crop, including linters, at 12,250,000 bales, while the second, accepting the Government estimate, figures the crop, including linters, at 11,911,000 bales. The first estimate puts American consumption at 7,000,000 bales and exports at 6,500,000 bales, of 13,500,000 bales; or a total while the figures given by the second are 6,000,000 bales for export and 7,250,000 bales American consumption, however, or a total of 13,250,000 bales. Mr. Watkins from says further that/the apparent surplus of 1,425,000 which is shown according to his figures,’'there must be de ducted 1,179,000 bales of linters, 429,000 carried over from last year and the linter crop of this year, 750,000, every bale of which will go into the manufacture of explosives. This cuts the spinner1s supply down to about 13,500,000 bales, leaving an apparent surplus at the close of the season i 976 -9- of about 250.000 bales*" I am informed that the Census Bureau in its statistics relating to the uses to which cotton is put, is confined to the consumption cf raw dotton, in cluding linters, and that additional legislation will be necessary to enable the Census Bureau to report on the con sumption of cotton which has been specially prepared or treated. At a recent hearing before one of the House com mittees it v/as brought out that the Census Bureau regards an estimate of 1,000,000 bales of cotton used in America during 1915 for the manufacture of explosives as conservative, and the statement was made at the time by the representative of the Bureau that it is possible that as much as 1,500,000 bales had been used in this way during the year in the United States. It has been estimated unofficially that 2,000,000 bales were used in Europe last year in the manufacture of l explosives, but I am told that the Census Bureau has no figures which throw any light upon the consumption abroad of cotton for this purpose. It is evident that muc& of the cotton now being exported to Prance is being used for ex plosives, as most of the cotton mills of Prance and all of those of Belgium are now within the German lines and are presumably not running for lack of cotton, although it is impossible to obtain definite information on this point. Swiss mills are said to be very busy, but their supplies of cotton have been cut off recently because they were supposed tO be selling to Germany and Austria* Consumption by mills in Norway and Sweden, Holland and Spain, would be abnormally large if they could get the cotton, but high freights and naval operations in the North Sea have rendered their supply precarious. Japanese mills will undoubtedly consume a great deal of cotton, but on account of proximity and lower freights they will probably take all they can from East India. The Russian mills are reported to be busy, but their supplies of American cotton must, for the present, come by way of Vladivostok, which means a long and expensive overland haul on a railroad congested with war material. The Port of Archangel however, which is ice-bound at present, will be open in May, and it is probable that Russia will q.dd to its stock of American cotton after that time. It is interesting to contrast the export movement during the present season with that of the last. The outbreak of the war in Europe on the first of August 1914 resulted in a practical stoppage of cotton exports until November. During December and January 1915, the movement abroad was heavy. While this movement was stimulated in February and March by the announcement of the forthcoming blockade of British waters by German submarines, the volume of exports continued satis factory until early in May, or until the sinking of the Lusitania. Prom this time on the export movement diminished appreciably and the advancing tendency in cotton prices was checked, followed by the slump in July, to which reference has already been made. During the present season, exports from August to November ran considerably ahead of the very light movement of the preceding year, but since November, owing to the reasons already outlined, the export movement compares unfavorably with that of the previous season, al though the movement for February compares well with that of February 1914. The decline in cotton prices seems to have been definitely checked about the first of March. It is said that several British merchant ships hitherto used as transports, are to be restored to commercial uses in the trade between New York and Liverpool. Italy and Portugal together have seized over 60 German steamers which have been interned in their ports, the presumption being that these steamers will be put into commission for mercantile purposes. At any rate, there has been an easing in ocean freight rates, which now show a decline of &0$/ per hundred, or $2.50 per bale from quotations current the latter part of February. Announcement was made a few days ago that 12 steamships are -IE- due to arrive at an early date at Galveston, which will load with cotton from that port® The latest issue of the Economic World, which is a recognized authority on the textile trade, has this to say regarding the demand for cotton: w The margin of profit between the cost of raw cotton and the market values of goods in the United States is now unusually wide, and it is the part of commercial wisdom for the manu facturer to secure fsrr himself this margin of profit, no matter what his inclination or judg ment may be with respect to a possible wider margin of profits in the future. This consi deration has induced a fair amount of buying for the account of American spinners during the past week. Were it not that much the larger part of the requirements of our mills for the season has already been secured, this buying might be counted upon as a sustaining and per haps even as an advancing influence in the markets for the imm§diate future. In addition to this buying for American account, some buying for foreign account has been in evidence.” The ability and disposition of the banks of this country to take care of the legitimate wants of their customers, as well as to carry well secured ‘loans for those who are not customers has never been greater than at present. At the close of business on March 6th the total of all paper under discount with Federal Reserve banks, including rediscounts for member banks, open market jjurchases of bankers1 acceptances, trade acceptances and commodity loans carried for member banks, was slightly over $51,000,000 against total deposits held by these 980 - 13- institutions 6f $454,761,000; while on January 2nd the amount of paper under discount was over $54,000,000 against deposits of $431,085,000. Except in the Richmond and Atlanta dis tricts the loans secure)! by cotton receipts are of a negligibl amount, and in these two districts they have been considerably reduced since the first of the year. The total bills dis counted with the Federal Reserve Bank of Atlanta, including the New Orleans Branch, was, on January 2nd, $8,200,000. On March 6th this amount had been reduced to $4,420,000. The amount of loans held by the Federal Reserve Bank of Richmond on January 2nd was $7,612,000, and on March 6th the amount of its loans was $6,433,000. The amount of discounted paper held by the Federal Reserve Bank of St. Louis cn January 2nd was $1,915,000, while on March 6th the amount was $1,429,000. The loans of the Federal Reserve Bank of Dallas on January 2nd amounted to $4,911,000, and on March 6th to $4,550,000. The same conditions are reflected in the state ments of member banks. In all sections of the country first class commercial paper is sought for at abnormally low rates, and I may say that for several months past the chief concern of the Federal Reserve Board over the monetary situa tion in this country for the immediate future has been that the unusually low rates prevailing in financial centers might lead to an unwise inflation of credits. There is every - 14- reason to believe that exports of cotton will continue on approximately the present scale during the spring and summer months, up to the close of the present cotton year, and there seems to he little danger of there being an unwieldy surplus carried over into the next season. There is undoubtedly a considerable amount of unsold cotton in the South which is being held by farmers and country merchants, but the amount is probably no greater than in some previous years, as the stocks reported at interior towns on March 3rd amounted to 1,080,000 bales, against 1,063,000 bales at the same towns on March 5th 1915. During the week ended March 3rd the in terior stocks decreased 35,761 balos, and receipts at all towns were 84,838 bales less than for the same week last year. Attention is invited to the Financial Chroniclers comparative statement of amount brought into sight and spinners1 takings for the weeks ended March 3rd, 1916 and March 4th, 1915: -15- In sight and spinners* Takings. Week Receipts at ports to March 3.......0.®.. 107,849 35,173 ifet overland to 3/5. Southern consumption 82,000 to March 3 ......... Total marketed... 225,022 Interior stocks in excess.............. *35,761 Came into sight dur ing week........... 189,261 Total in sight 3/4.. Uorth spinners* tak ings to March 3.... 34,396 *Decrease during week. 1915-16 Since Aug. 1 1914-15 Week Since Aug. 1 5,402,039 1,011,489 284,634 31,314 8,093,162 921,677 2,190,000 60,000 1,830,000 8,603,528 375,948 10,844,839 634,711 *64,959 943,420 310,989 11,788,259 9,238,239 88,743 2,135,026 2,047,309 Movement into sight in previous years: Week1914 March 6 1913 March 7 1912 March 8 Bales 198,304 154,692 281,157 Since Sep t .1. 1913- 14 March 6 1912- 13 March 7 1911- 12 March 8 Bales. 12,673,042 11,856,556 13,421,418 Some private letters that I have received state that there were perhaps two million hales of cotton held on March 1st by Southern farmers and local merchants. If all of this cot ton, or any large part of it should be thrown upon the market at once, there would undoubtedly be a break in prices. But five months, or about 21 weeks will elapse before any new cotton can cone on the market. With the demand for export and from American spinners which seems assured, there is no reason to ('Q9 • O ) - 16- doubt the ability of the market to absorb much more than 100,000 bales per week. I refrain however, as I have always done, from giving advice in particular cases, I believe that the policy of gradual and orderly marketing of the crop has been proved to be the correct one by the course of the market this season, and, while there are no doubt many holders of cot ton who will regret that they did not sell when prices were higher, it is no doubt true that the higher prices last fall were obtainable by reason of the fact that there was s^o un seemly rush of cotton to the market; ownership, and, without regard to it is safe to assume that the cotton held back has contributed its part to the prices realized for cotton that has been sold. I wish that each individual farmer would remember*, when the time comes for him to determine how much of his land he will put in cotton this spring, that we are living in unusual anft times and that it is impossible for any man or/group of men to forecast with certainty what the consumption of a staple like cotton will be. I believe in the gradual and orderly marketing of crops, but I believe just as firmly in the diversification of crops. i'a,rmers of the Northwest who produce the bulk of th^ great food crops of this country, have learned that it is dangerous to place reliance in one crop, even though it be a food crop, and, while they cannot raise cotton^ they diversify by planting different kinds of grain, and by producing more than 984 -17- one kind of food. I quote q statement that was made recently by a prominent bank in the Northwest: "The investment market does not seem to be as active as the large amount of money in banks and the heavy savings balances would ordinarily indicate. General interest rates are so low that many people are con tent with savings bank interest. The demand for farm mortgages is very strong, but our farmers are in such excellent condition financially that the supply of mortgages continues to be less than the demand. This, of course, has resulted in a decrease of rates to the farmers. Mortgages from the best farming communities of Minnesota and the Dakotas are especially hard to obtain. In former years, when there were plenty of these securities, it wq,s not necessary for capital to go into the newer parts of the Northwest unless attracted by high rates. It is probable that present conditions will turn large amounts of money to investment in the less populous portions of the Northwestern States and will result in increased settlement and greater value for land. Whether this condition will result in an extended movement ’'back to the farm,1 cannot, of course, now be predicted, but tendencies in that direction have already been reported from two or three sources.” I am sorry that I cannot yet quote similar statements from Southern sources, but I think within a few years, after the South has learned the lesson of diversification, that like con ditions will prevail, at least in favored sections. subscribe to the I wish to loctrine that is being and has been for years so effectively preached by one of the best known, and perhaps the most useful citizen of Alabama, Mrs. G. H. Mathis, who has a message of cheer and hope wherever she goes and who inspires thedispirited with new hopes and aspirations. diversified farming. She believes in She says that farming is a good business 985 -18but she warns the farmer that "the ground is sick of one crop. It is sick of cotton and by running the land down you are having to mortgage your property to death, and are making the crop self-consuming. Build it up. There are certain robber crops and certain builder crops that everyone ought to know. robber crops are cotton, corn, wheat and oats. are peas, The The builder crops beans, clovers and vetches, and you can build the land in winter when it is not in use.M I am told that there are farmers in Alabama, and perhaps in all Southern states who have never grown a stalk of corn. Let the farmersrealize, and I urge upon merchants and bankers the importance of persuading them, that an increased acreage in cotton will be looked upon as an arguipent in favor of lower prices for the remainder of the crop now being held, although it is by no means certain that a large acreage would yield a larger crop than a smaller and better cultivated area. Let us suppose things turn out this year as some optimists predict. Suppose peace should be restored and there springs up a greatly . increased demand for cotton. Under such conditions a large crop would of course sell for a great deal of money, but with the experience of 1910 and 1911 before us, is there any reason to doubt that a moderate crop would sell for still more? other hand, suppose the war continues; On the suppose, unhappily, this 986 - 19- country should become involved, — and remember that in times of stress, when it comes to a choice between something to eat and something to wear, food must be provided at any cost, while new clothes can wait. Then I ask, would we not be far better off with a moderate supply of cotton and an abundance of food supplies? thoroughly? Why plant a larger area than can be cultivated Why scatter high priced fertilizer over a large field when it would be more effective concentrated on a smaller? These matters must be determined nowj too late? A month hence will be Let the farmers, the merchants and the bankers cf the South take counsel together, and let the newspapers, and those published at the county seats particularly, advocate in every issue for the next six weeks, and with all their force and power, the doctrine of diversification, and let them point out the dangers of the one crop system^ Remember, my friends, that if the war continues for six months longer, in all probability the purchasing power of Europe will be seriously impaired. The cost of munitions and supplies is enormous, and food prices in the warring countries are soar ing. According to the Bureau of Labor Statistics of the Department of Labor, good, taken as a whole in the United States costs Ztfo more today than it did a year ago. Prices in Great Britain have increased about 44$ and in Prance about 22$. In r 07 -BOother "belligerent countries the advance has *been 1 0 0 % , Remember that the cotton exchanges are not eleemosynary in stitutions, and that operators on cotton exchanges have no sentiment except a desire for gain, Market opinions vary as conditions change, and operators are not consistent bulls or bears, but shift their position without notice as new condi tions arise. The fact is realized in all the cotton markets of the world that the course of prices depends primarily upon the supply, and for the next three months at le^st, estimates of supply will be based upon the new crop acreage. What this acreage will be in America depends upon the farmers of the South* Should they decide during the next few weeks to pro duce their food stuffs at home and to plant cotton as a money crop, their position will be secure, but if, disregarding all the warnings and portents of the times, they decide upon a policy of all cotton, they will be taking a tremendous risk which no prudent business man would care to assume. The Southern farmer is most powerful as a factor in the cotton market at planting time. "Every man at times is master of his fate# « The fault, dear Brutus, is not in our stars, hut in ourselves, That we are underlings." 6oi. wier.fnB«Br)*Ju III RE PAYMENT OF DIVIDENDS BY FEDERAL. RESERVE BANKS. PAYMENTS, UPON HEW STOCK SUBSCRIPTIONS. AND PAYMENTS UPON STOCK SURRENDEREDi 1* (a) Dividend Payments. The Federal Reserve Board should he advised hy the officers of the Federal reserve hanks when it is the intention to sub mit the question of the payment of dividends to the direct ors at the next meeting. At the same time the hank should submit to the Board the information as called for in the at tached memorandum marked "A". (h) Dividends to he paid annually, if earned. Books to he closed at the close of business December 31st. The suggested form of dividend resolution, which has been prepared by Judge Elliott, is attached to this memorandum and marked nB u. Undistributed earnings are to he carried in the profit and loss account. No transfers should be made to surplus account until such time as accrued dividends have been paid to date* Accrued dividends, or interest on capital stock payments, are to be figured at the rate of l/2$S per month. The dividend distribution should ho based upon the earnings for the year. Accrued dividends for previous year to he first paid, balance to he applied on divi» dend for current year. 2* (a) Additional stock: Payments on additional stock sub scriptions of member banks. Until cuch time a3 dividends have been paid in full to the last "regular dividend date, new stock is to be paid for at par. When accrued dividends have been paid -to date, ■ k 990 - 2 - 601. stock subscriptions during the following year are to be paid for at par, plus l/2 per cent per month since the last regular dividend date, if earned. (b) Stock subscriptions of new mesbar h^nksr Rule outlined in pre ceding paragraph should govern. 3* Capital stock surrendered for payment and cancellation. Until such time as a reserve bank has retired its organization expenses, surrendered 3tock should be paid for at par, un less a material actual impairment is shev-n, or unless un distributed earnings are sufficient to pay all accrued, cur rent and organization expenses. If a profit and loss surplus ha3 been accumulated, after allowing for expense iteir.3 referred to in previous paragraph, surrend ered stock is entitled to share in such undistributed earnings as are shown by the books of the reserve bank on the last day of the preceding month, to bs figured as follows: Profit and loss account ______________ Current earnings (including all accruals) . ______________ ______ Less: Current expenses, including, cost of Federal reserve notes used to date, allow ance for depreciation in furniture and vaults, and depreciation in real estate, and accrued expenses not paid but cnargenble to period. ____________ Estimated l o s s e s ____________~ Estimated net undistributed earnings ______ Under the circumstances outlined, the surrender value of stock .will 991 601. -3- be par,, plug a share of the net undistributed earnings in the proportion which the accrued dividend or unpaid interest on the stock surrendered hears to the total accrued dividends cn the stock of member bank3, up to the close of business on the last day af the preceding month, i. P~r T Iffot undistributed earnings after making allovtences for accruals, depreciation and estimated losses- i- * Accrued dividend on stock surrendered Total accrued dividends all member banks within district. Payments for additional stock and repayments to member banks for stock surrendered, should bG made at regular periods, say*, quarterly. 99S 601 "A" Statement of Earnings to be filed with Federal Reserve Board prior to a declaration of dividend* Earnings since Jan. 1, 191 . Rediscounts Warrants Acceptances Commissions Other sources Accrued earnings (not credited) Current expenses Expenses paid, chargeable to period sinc9 Jan 1st __ Accrued expenses to Is^t aay previous month __ Cost of Federal reserve notes used . Allowance for depreciation m vaults and equipment __ Depreciation m real estate __ I7et earni jgs Jan 1, 191_ Profit and Loss Account ______ Less interest payments maae on stock surrendered since Jar. 1, 19J._ ______ Profit anl loss balance after allowing for net earnings since Jan. 1, 191__. E3tirated losses Available for distribution* 1 Suppleiaertal Information 1. Unpaid indebtedness of closed banka to reserve banks. Give list, show if notes are sectored, notes jd'.ich nave been past 4.a six months or loiger, estimated losses. 2. Member banks considered to be in over-extended or unsaio condition. Give names of banks, indebtedness to Federal reserve bank, and a memorandum of security, if any. 993 "A" 6oi. - 2 - Dividends. Available for dividend payments Dividend payment to be recommended to the Board of Directors: Per cent _____ Amount Profit and loss account after allowing for proposed dividend payment NOTE: In the opinion- of the Federal Reserve Board, there should be retained in the profit and loss account an amount equal to (a) Total of notes or other obligations bearing the endorsement of failed banks when such obligations have been pa3t due six months or longer* (b) 1C$ of net earnings to provide for unexpected » ' expenses or losses. (During the first few years)* Accrued Dividends. Interest on capital stock payments to Dec. Jlj 1915 Dividends paid to data Accrued and unpaid dividends to Dec. Jl, 1915 Accrued dividends - current year ( estimated ) Total accrued dividends to date Estimated dividend payment to be recommended to Board of Directors Estimated balance unpaid dividends after allowing for payment to bo recommended, to the Board of Diroctors 6$ 994 . -601- PESOLtiTIOF FOR DIVIDEND* WHEREAS, The officers of this association, hav© sirtanitted to the Federal Roserve Board a statement of condition m form approved by the Bo?rd, w m c h statement has been duly certified by a committee appointed by this Boards and has been ordered spread upon the minutes of t m s meeting,, and WHEREAS, It appears from this statement that the estimated accrued dividends due the stocKioldsrs on , , — °* ■ ■■ ■■■■will amount to $ ,__________and that after charging to profit and lass account all expenses, whether paid or acOrued which are prop erly chargeable as current expenses, and efter making provision for any depreciation th?t uay nave occurred m the vrlue of tho assets owned by the b?nk and for probable losses, t h e n will rericm m said profit and los3 account the sum of $ t , ----» 110% THEREFORE, BE IT RESOLVED, that a dividend to stock holders of _ _ _ _ _ per cent, payable on day of , be, and is hereby declared on all stock of this bank as shown by the books of the bank on that date. BE IT FURTHER RESOLVED, that e copy of this resolution be transmitted to the Federri Reserve Board and upon its epproval that the officers of this oank be, and they ere hereby, authorized and directed to pay and distribute to said stockholders the divi dend so declared, *That after the payment of all accrued dividends, and after provision has been made for all expenses, losses and de preciation m assets, s?id officer® are authorized, empowered and directed to charge to profit and loss account and to credit to the surplus account of this bank the sum of S . and pay the balance r e m r i m n g to the United States as a franchise tax as provided by law. * This part of the paragraph to oe used after full dividend*, nave been paid to date. V3/16 602. T R E A S U R Y D E P A R T M E N T WASHINGTON. April j j 1916 . Charles S. Hamlin, Esq., Governor, Federal Reserve Board, Washington, D. C. S i r : In response to your communication of the 27 th ultimo, enclosing copy of a letter from the Carter White Lead Company, West Pullman Station, Chicago, Illinois, you are advised that drafts, acceptances, overdrafts and post-dated checks, are not taxable under the Act of Octo ber 22 , 191^, as promissory notes. Your attention is invited to paragraph I of T. D- 2170, as follows: (l) In view of the decision made by the Supreme Court of the United States in the case of the United States v. Isham (17 Wall, H06), that "the liability of an instrument to a stamp duty, as well the amount of such duty, is determined by the form and face of the instrument, and can not be affected by proof of facts outside of the instrument itself," this office is of the opinion that drafts, accept ances, overdrafts, and post-dated checks are not taxable under the above act as promissory notes, even though they are used in such a way as to per form some of the functions of a promissory note. Respectfully, DAVID A. GATES, Actin'g Commissioner. W. P . G. HARDING, GOVERNOR P AU L M. WARBURG, VICK GOVERNOR FREDERIC A. DELANO ADOLPH C. M ILLER CHARLES S. HAMLIN Ex -O ffic io Members W ILLIAM G. McADOO SECRETARY OF THE TREASURY C h a ir m a n JOHN SKELTON W ILLIAM S COMPTROLLER OF THE CURRENCY H. PARKER W IL L IS , SECRETARY SHERMAN P. A LLE N , ASST. SECRETARY FEDERAL RESERVE BOARD AND FISCAL AGENT -606ADDRESS REPLY TO W A S H IN G T O N FEDERAL RESERVE BOARD April 7* 19l6» My dear Mr. On behalf of the Committee of the Federal Reserve Board on the subject of check clearing and collection, and on behalf of the Board, I am send ing you herewith a memorandum prepared by myself, giving the reasons, as I see them, why it is im portant for the Board to males progress in this mat ter at this time* ^ I am also enclosing herewith copies of four planswhich have been submitted to the Board since the six plans which were sent to you recently*- These four plans have been mimeo graphed and bound together. At this writing the Board has also just, received a plan prepared in parallel columns by the officers of the Federal Reserve Bank of St. Louis and submitted by them, but this plan, having been prepared on a wide carriage machine in parallel columns, has not yet been mimeographed. However, we will endeavor to have this plan copied and sent to you within a few days. Yours very truly, )n W . P. G. HARDING, GOVERNOR P A U L M. WARBURG, V ic e G o v e r n o r FREDERIC A. DELANO ADOLPH C. M ILLER CHARLES S. H A M LIlf Ex -O ffic io Members W ILLIAM G. McADOO ^609. SECRETARY OF THE TREASURY C h a ir m a n JOHN SKELTON W ILLIAM S Co m p t r o l l e r o f t h e c u r r e n c y FEDERAL RESERVE BOARD W A S H IN G T O N H. PARKER W IL L IS , SECRETARY SHERMAN P . ALLE N , ASST. SECRETARY AND FISCAL AGENT AD D R E SS R E P LY TO FEDERAL RESERVE BOARD April 11, 1916. Dear Sir: The Federal Reserve Board has had under discussion with the Treasury Department, particularly with Assistant Secretary Malburn, suggestions which have come to it at various times that National hanks he permitted to make deposits to the credit of the Five Per cent Fund in the hands of the Treasurer of the United States at Washington through their own Federal Reserve Banks, ana that, if this can he arranged, it will enable Federal Re serve Banks to render an important and desirable service to their members* The rule heretofore has required National hanks to get drafts on New York, hut it is now suggested that that instead of requiring this, the hanks may properly he per mitted to request their own Federal Reserve Banks to remit to the Treasurer of the United States for their credit in the Five Per cent Redemption Fund. This would then he handled (in denominations of $10,000) and at the convenience of the Federal Reserve Bank of the District, through the Gold Redemp tion Fund at Washington. In carrying out this plan it is proposed that the Federal Reserve Bank of New York shall have the privilege of 609- - 2 - paying for its member banks directly to the Assistant Treasurer of the United States in that city, and, furthermore, it is the idea that nothing in this plan shall prevent National banks from making remittances direct to the Treasurer of the United States or to the Assistant Treasurer at Hew York in the cld way if they do not choose to avail themselves of the method herein proposed. As this is e. natter in connection with the operation of the Banks which nay well bo considered cy the Governors at their forthcoming conference in Washington, it is now submitted to you with the request that you take it up at that tine and offer such suggestions or conclusions as you may have arrived at. Yours very truly. Vice Governor April 12, 1916 Sir: Some months ago the Federal Reserve Board decided that hereafter a copy of the report of examination of each Federal Reserve Bank should be given to the respective bank. It has no-,? boon suggested by one of the Governors that, in order to insure dissemination of these reports, the Federal Reserve Bank should in each case request each of its Di rectors to read the report, initial it, and that the Chair man of the Board of Directors shall notify the Federal Re serve Board that the report has been read by these Directors, and, therefore, had their full consideration. The Federal Reserve Board would be very glad to have this course adopted in the future. Yours very truly, Governor fill. COLLECTION OP OUT OP TOWN CHECKS BY FEDERAL RESERVE BANKS. (By W*. P. Gl Harding) This is a matter that has engrossed the attention of the members of the Federal Reserve Board and of the officials 6 f the various Federal Reserve Banks, for more than twelve months. It has been the subject of many conferences and several plans have been suggested. The problem involves the handling of checks by a Federal Reserve Bank for its own member banks and also inter-bank transactions. The Gold Settlement Fund which was established by the. Board about a year ago, may be regarded as a satisfactory method of adjusting balances .between Federal Reserve Panics. In seeking a solution of the problems involved in the intra-district transactions, it would bo well for the Federal Reserve Banks to approach the subject from the same angle that a newly established member bank would in its efforts to build up a profitable business. It should be borne in mind that the Federal Reserve Banks are not required or permitted to receive checks on deposit from the general public, but their contact with checks is limited to such as they may receive from their own depositors (their member banks) or from other Federal Reserve Banks. There has been no pressing need for radical changes in the present methods of collecting country checks,_ 1001 611 - 2 - ■ an evolution after years of experience,— but, as has been pointed out frequently, it is the relation between the country check and the reserves which must be considered. After November 1917 no balances in any bank other than a Federal Reserve Bank will be permitted to count as reserve and it is probable that balances hitherto carried by country banks with their national bank reserve agents, will .either be cartailed appreciably or withdrawn entirely. There is, always has been, and always will bo, an actual expense attached to the collection of country checks. Possibly this expense may be reduced under the clear ing methods of the future just as it has been reduced in the past, but there is no doubt that many banks have been deceiving themselves into thinking that they are put to no expense in the collection of their country checks, while an analysis . would show in many cases that banks pay this expense indirectly by carrying balances Tilth collecting bonks that might be more profitably employed otherwise, and that they are really paying more for a collection service than other banks who meet the expense face to*face and settle it as it accrues. Reserve Bank is a purely mutual organization. A Federal Its depositors are its stockholders and its borrowers aro ell stockholders. Each Federal Reserve Bank should hold itself ready to serve each one of its limited number of depositors as far as it can ±002 - 611 3- with safety to itself and with justice to its other depositor stockholders. Should any member hank desire to discontinue ' national hank reserve accounts that it has been carrying and rsk a Federal Reserve Bank for the same collection facilities that had been extended by the Rational Bank reserve agent, such service should, without hesitation, be extended by the Federal Reserve Bank; not, however, at a loss to itself, which would be unfair to its other stockholding banks, but at cost or as near to cost as practicable. If the member bank which has been in the habit of counting as reserve, items in transit to its national bank reserve agent, desires the same privilege as to items sent to Federal Reserve Banks, it should be granted. But the Federal Reserve Bazik should analyze each account m order to determine the average amount of outstanding items or float that it has permitted the member bank to count as reserve, and it Should charge interest upon whatever amount of the opparent reserve cairied is found to be made up of checks m transit. The actual cost of collection should ^lso be ascer tained and the proper allowance mad* for overhead charges. A statement of all this should be rendered the member bank once a month and the resulting charge made against its account. Ihe Federal Reserve Bank should give full service to the member bank, including checks on state banks and tiust companies and 1003 611 . -4 checks drawn on other banks m other districts, but it should require as a condition precedent, that each mcniber bank sending checks for credit should agree that checks upon it may be charged against its account with the Federal Reserve Bank, immediately apon receipt by the Federal Reserve Bank, as a matter of convenience;— but on the books of the member bank as a matter of course, not until the member bank had received the items. In the analysis of the account to be made daily hnd rendered monthly by the Federal Reserve Bank, allowance should be made m time m computing the float against a member bank of the transit to it of items charged against its account on the books of the Federal Reserve Bank. By following these principles, which are based merely upon the idea 6f adequate service vith a compensating charge, the Federal Reserve Banks will gradually assume for their mem bers the burdezi of collecting out of torn checkSi But it is not anticipated that the change will take place so rapidly as to embarrass the Federal Reserve Banks physically or otherwise. The actual cost which must be met frankly *nd 7hich cannot be disguised or diluted, will no doubt appear high at first, and will cause many member banks to be slow to use Federal Reserve Banks as collecting agencies; but the fact that balances with Federal Reserve Banks count as reserve while those v/ith other \ 611 banks will not, will be a powerful leverage in the long run, and assuming that each member bank that uses its Federal Re serve Bank as a collecting agent will be required to permit the chafcge of checks on it against its account at par, it follows that the cost of handling items by a Federal Reserve Eank will be reduced from time to time as one member bank after another uses the Federal Reserve Bank as a reserve correspondent and collection agent* banks, — Those who deposit checks with the member the public — are already in many instances, owing to close competition between bonks, getting free service, others may be paying by carrying free balances, while still others may be subjected to direct and sometimes excessive charges. But it is evident that as member banks are enabled to collect out of town checks at a reduced cost, this benefit will inure, in tb p last analysis, to their customers* Bo not get away from the fact however, that the problem of collecting country checks with which the Federal Reserve Banks are con fronted, is not one which has to do directly with the public, but concerns primarily the member banks. of banking practice; It is purely $ matter it should.be worked out on the basis of adequate service and proper compensation for service rendered. Washington, B. C. Apr^l 15, 1916. 1005 612 T R E A S U R Y D E P A R T M E N T WASHINGTON April 12, 1916* Hon. C. S. Hamlin, Governor, Federal Reserve Board. Sir: Your letter of the 10th instant is received in which you say, "There is some apprehension on the part of the Federal Reaseve Bank of Philadelphia because of the fact that instructions were at some time given to the Assistant Treasurer at Philadelphia to pay withdrawals of funds held by the Federal Reserve Bank of Philadelphia in the Gold Settlement Fund in 'any available funds1.n You ar9 advised that such instructions were recently wired for the purpose pf facilitating the payment, and not of changing the kind of funds payable on such transactions. It is the understanding of this office that all'deposits to the credit of the Gold Settlement Fund are to be made in gold, gold certificates or gold order certificates, and that all pay ments under the said fund shall, where gold is available at sub treasuries, be paid in gold or its equivalent,* and that in case such funds are not available, shipments thereof will be made at the expense of the Gold Settlement Fund for such payments. Respectfully, JOHN BURKE, Treasurer. J .0.14 616 DEPARTMENT OF JUSTICE, Washington. April 14, 1916. Sir: At the request of the Federal Reserve Board, you have submitted the following questions for my opinion: 1. Can the Federal Reserve Board legally change the present location of any Federal reserve bank: (a) In the case where there has been no alteration in the district lines, and (b) In the case where there has been such readjustment of district lines as in the opinion of the Board necessitates the desig nation of a new Federal reserve city in order that due regard may be given to the convenience and customary course of business as required by Section 2 of the Federal. Re serve Act? 11. Must the Federal Reserve Board, in exercising its admitted power to readjust, preserve the $4,000,000 minimum capitalization required of each Federal Reserve bank as a condition precedent to the commencement of business? 1. In my opinion of November 22, 1915, I expressed the view that the "Federal Reserve Act" does not confer on the Federal Reserve Board the power to abolish any of the existing Federal reserve banks or Federal reserve districts. I believe that the reasoning of that opinion is equally applicable to both branches of the first question now submitted. Section 2 of the Federal Reserve Act provides: As soon as practicable, The Federal Reserve Bank Organization Committee shall designate not less than eight nor more than twelve cities to he known as Federal reserve cities, end shall divide the continental United States * * * into districts, each district to contain only one of such Federal reserve cities. The determination of said organization committee shall not be sub ject to review except by the Federal Reserve Board when organized: Provided. That the dis tricts shall be apportioned with due regard to the convenience and customary course of business and shall not necessarily be coterminous with any State or States, The districts thus creat ed may be readjusted and new districts may from time to time be created by the Federal Reserve Board, hot to exceed twelve in all. Such dis tricts shall be known as Federal reserve dis tricts and may be designated by number. * * * Said organization committee shall be authorized * * * to make such investigation as may be deemed necessary by the said committee in determining the reserve districts and in designating the cities within such districts where such Federal reserve banks shall be sever ally located. The same section further provides: The said committee shall supervise the organi zation in each of the cities designated of a Feder al reserve bank, which shall include in its title the name of the city in which it is situated, as "Federal Reserve Bank of Chicago." Since the Act thus provides that each city designated as a Federal reserve city is to be the location of a Federal reserve bank, it follows that a change in the location of a Federal reserve bank would in effect be the designation of a new Federal reserve city and the abandonment of one pre viously designated. I find no more warrant in the Act for the abandonment of one Federal reserve city and the designation of a new one than I do for the abolition of a Federal reserve district when once established. The power to designate a new Federal reserve city (twelve cities having been named by the Organisation Com- 1008 616 -3 - mittee), or to change the location of a Federal reserve hank, is not expressly conferred hy the Act on the Federal Reserve Board. If the Board possesses such power it is only hy implication from the provision that— The determination of said organization com mittee shall not he subject to review except hy the Federal Reserve Board when organized; Provided. That the districts shall he apportioned with due regard to the convenience and customary course of business and shall not necessarily he coterminous with any State or States. The districts thus creat ed may he readjusted and new districts may from time to time he created hy the Federal Reserve Board, not to exceed twelve in all* In my opinion there is no clear indication, either in the provision just quoted or elsewhere in the Act, of an in tent to confer on the Federal Reserve Board the power to change the location of Federal reserve hanks hy the designa tion of new Federal reserve cities. On the contrary, there are indications of an opposite intent. As stated in my opinion of November 22, 1915, above referred to>*tt The merely negative statement that the determi nation of the Organization Committee "shall not he subject to review except by the Federal Reserve Board when organized" clearly cannot he enlarged into an affirmative grant of power to the Board to review and set aside everything done hy the Organi zation Committee, The reasonable view is that by that language Congress meant that the determination of the Organization Committee should not he subject to review at all, except in so far as the subsequent provisions specifically authorize a review hy the Federal Reserve Board. The only subsequent provision authorizing a review of the determination of the Organization Committee hy the Federal Reserve Board is contained in the sentence— "The districts thus created may be readjusted and new districts may from time to time he created hy the Federal Reserve Board, not to exceed twelve in all." Again, as stated in that opinion,— "A reading of the Act shows at once that the Organization Committee was created not merely for the purpose of attending to the formalities of organi zation or to serve as a stop-gap until the Federal 1009 616 -4 - Reserve Board should come into existence, but that it had an independent function to perform and to that end was invested with wide powers. That is to say, its function was to organize the system as contradistinguished from the func tion of the Federal Reserve Board, which was primarily to administer the system. The duty of designating Federal Reserve cities belonged to the Reserve Bank Organization Committee as a part of the organization of the system, and the Committee was required by the Act to designate not less than eight nor more than twelve cities. This duty is named first among those imposed upon the Organization Committee, and it is imposed by the same provision of section 2 which required the Committee to divide the United States into Federal Reserve districts. The same considerations that indicate an intention that the several districts should be permanent would also indicate that the designation of the cities was not to be made for temporary purposes, but was intended to be permanent, subject, of course, to change by Congress, The designation was to be made only after thorough investigation> and the same machinery was provided to facilitate both the determination of the districts and the designation of the cities. Thus, Section 2 provides: Said Organization Committee shall be authorized to employ counsel and expert aid, to take testimony, * * * and to make such investigation as may be deemed necessary * * * in determining the reserve districts and in designating the cities within such districts where such Federal reserve banks shall be severally located. In my opinion, this coupling of the duty of determining, the districts with the duty of designating the Federal reserve cities within the several districts shows an intention on the part of Congress that the cities so designated are to con stitute the fixed centers in the scheme or system of division, 1.010 -5- 616- the duty of designating the cities being coordinate with the duty of forming districts around them. It was left to the discretion of the Organization Commit tee whether it should designate the full number of Federal reserve cities and establish the full number of Federal reserve districts permitted by the Act. The committee elected to designate and establish the full number authorized, thereby practically suspending the operation of the provision of the Act that "new districts may from time to time be created by the Federal Reserve Board not to exceed twelve in all. " The prim ary if not the only purpose of that provision must have been to take care of the situation in the event that the Organization Committee had designated less than twelve Federal reserve cities. The fact that the Federal Reserve Board, aside from the provision relating to the creation of new districts from time to time, was merely given the power to "readjust" districts suggests that there was to be some permanent characteristic or element in the districts created by the Organization Committee. If, however, in addition to the power which the Federal Reserve Board has of readjusting districts by changing their boundary lines, it also possessed the power to change the location of the respective Federal reserve cities within such districts, then the Board could, by successive changes ±011 6i6 - 6 of cities and boundaries, entirely obliterate existing districts and substitute in their place new districts to tally different from those created by the Organization Com mittee. X do not think that Congress intended to confer such a power. The Act provides that each Federal reserve bank is to include the name of the city in which the bank is located. By Section 4 it is provided that the organization certifi cate of each bank shall state specifically - The name of such Federal reserve bank, the ter ritorial extent of the district over which the opera tions of such Federal reserve bank are to be carried on, the city and State in vhich said bank is to be located, the amount of capital stock and the number of shares into vhich the same is divided * * *. Upon the filing of such certificate with the Comptroller of the Currency in the manner prescribed, such Federal reserve bank - shall become a body corporate and as such, and in the name designated in such organization certificate, dhall have power - * * * * * * have succession for a period of twenty years from its organization unless it is sooner dissolved by an Act of Congress, or unless its franchise becomes forfeited by some violation of law. (Sec. 4.) It is to be noted that there is no provision in the Act by which the Federal Reserve Board may change the name of a Federal reserve bank or amend its certificate in this re spect. The whole tenor suggests permanency. The omission of Congress to grant, by express language, the power to change Federal reserve cities is significant, especially in view of the language of Section 11 (e) of the Act, which confers the power - - ±013 -7 ■616' To add to the number of cities classified as reserve and central reserve cities * * *; or to reclassify existing reserve and central re serve cities, or to terminate'their designation as such. It would have been equally easy, had Congress de sired to grant the authority to designate new Federal reserve cities, to have said so in express terms. (Tillson v. United States . 100 U. S., 43, 46, quoted in my opinion of November 22, 1915, supra.) It may be suggested that changes in the "custom ary course of business" or other changes not foreseen by the Organization Committee may result in inconven iences which the Federal Reserve Board cannot remedy if its power to change the location of Federal reserve cit ies is denied. The answer is that the remedy is with Congress, in so far as it may not already be supplied by Section 3, which authorizes the establishment of as many branch banks in any district as may be found ex pedient. To sum up my conclusion on the question of whether the Federal Reserve Board can legally change the present location of any Federal reserve bank, I am of opinion that the Board has no such power, and that such power is lacking whether there has been an alteration or readjust ment in the district lines or not. 1013 * 6i6 - 8 - I I . Coming now to the consideration of the second question submitted, namely; whether the Federal Reserve Board; in exercising its admitted power to readjust; must preserve # the $4;000;000 minimum capitalization required of each Fed eral reserve hank as a condition precedent to the commence ment of business, I am of opinion that this question is to he answered in the negative* The Federal Reserve Act provides in Section 2: No Federal reserve hank shall commence husiness with a subscribed capital less than $4;000;000. The some section also contains a provision requiring subscriptions to the capital stock to be paid - One-sixth * * * * on call of the Organization Committee or of the Federal Reserve Board; onesixth within three months and one-sixth within six months thereafter; and the remainder of the subscription; or any part thereof; shall be subiect to call when deemed necessary by the Federal Reserve Board * * * . Section 4 contains the following provision: When the minimum amount of capital stock prescribed by this Act for the organization of any Federal reserve bank shall have been sub scribed and allotted, the organization commit tee shall designate any five banks * * * * to execute a certificate of organization * * * * . Upon the filing of such certificate with the Comptroller of the Currency the said Federal reserve bank shall become a body corporate. The decrease of capital stock is authorized by the fol lowing provision of Section 5 5 The outstanding capital stock shall be increased from time to time as member banks increase their capital stock and surplus or as additional banks become meinbers, and may be decreased as member banks reduce their capital stock or surplus or cease to be members. 1014 % 6l6 - 9 - Additional provisions relating to the decrease of capital stock are found in Section 5 and 6, as follows: Sec. 5 . * * * * VJhen a member bank reduees its capital stock’it shall surrender a proportionate amount of its holdings in the capital of said Federal reserve bank, and when a member bank volun tarily liquidates it shall surrender all of its holdings of the capital stock of said Federal re serve bank and be released from its stock subscrip tion not previously called. In either case the shares surrendered shall be canceled and the mem ber bank shall receive in payment therefor * * * a sum equal to its cash-paid subscriptions on the shares surrendered * * * less any liability of such member bank to the Federal reserve bank. Sec. 6. If any member bank shall be declared insolvent * * * the stock held by. it in said Fed eral reserve bank shall be canceled * * * and all cash-paid subscriptions on said stock, with onehalf of one per centum per month from the period of last dividend, not to exceed the book value thereof shall be first applied to all debts of the insolvent member bank to the Federal reserve bank, and the balance, if any, shall be paid to the receiver of the insolvent bank. Whenever the capital stock of a Federal reserve bank is reduced, either on account of a reduction in capital stock of any member bank or of the liquidation or insol vency of such bank, the board of directors shall cause to be executed a certificate to the Comp troller of the Currency showing such reduction of capital stock and the amount repaid to such bank. In Section 9 it is provided: If at any time * * * a member bank has failed to comply with * * * the regulations of the Federal Reserve Board, it shall be within the power of the said board, after hearing, to require such bank to surrender its stock in the Federal reserve bank; * * * * and said Federal reserve bank shall, upon notice from the Federal Reserve Board, be required to suspend said bank from further privileges of membership, and shall within thirty days of such notice cancel and retire its stock and make pay ment therefor in the manner herein provided. It will be observed from the foregoing quotations that the Federal Reserve Act expressly provides that no Federal reserve bank shall commence business with a sub- 1015 scribed capital of less than $4,000,000. ( Sec. 2. ) They were each to be organized when the minimum amount of capital stockhad been subscribed. ( Sec. 4). Only Jt three-sixths of the capital subscribed is required to >W be paid in, the remainder being left " subject to call when deemed necessary by the Federal Reserve Board. " (Sec. 2. ) The Actt specifically provides for the decrease of capital stock (l) as member banks reduce their capital stock; and (2) as they cease to be members. ( Sec. 5.) Member banks may cease to be members for any of four causes - |a) Voluntary liquidation (Sec. 5); (b) Insolvency ( Sec. 6); (c) Violation of regulations of Federal Reserve Board (Sec. 9 ); (d) Transfer from one Federal district to another through readjustment of districts (Sec. 2). The Act specifically .requires the cancellation of capital stock where membership ceases under (a), (b) or (c). Secs. 5, 6 and 9 .) No specific provision is made for cancellation of capital stock where membership ceases under (df). While the minimum Capital had to be subscribed in order to comroence business, the maintenance of that minimum is nowhere prescribed by the Act. The fact that the Board is to determine whether more than half the subscrip tion is to be paid in seems to indicate that the minimum to be subscribed was fixed as a precaution to make sure that ample credit should of the system. be pledged to insure the success Not only is the maintenance of the minimum not pre scribed, but express provision is made for reducing the capital stock as, or whenever, member banks "cease to be members." This language is general and includes in its terms all cases in which member banks cease to be members,. It is coupled with no expressed condition that the mini mum capitalization be preserved; and since the Federal Re serve Act required the organization of the Federal reserve banks upon the subscription of the minimum, it is obvious that any reduction whatever made after commencing business might reduce the capital below the minimum. It is plain that a member bank can be a member only of the Federal reserve bank of the district in which both are located. This is obvious from the nature of- the Federal re serve districts and is assumed in Sections2, 4 and 9* Of necessity, therefore, when the Federal Reserve Board, in the exercise of its power to readjust, transfers a member bank from one district to another, such transferred bank must cease to be a member of the Federal reserve bank of the district from which it is transferred. When it thus ceases to be a member> the capital of the Federal reserve bank may be reduced; and there is nothing in the Act requir ing the reduction to be made subject to the maintenance of a minimum capital. It is to be noted that Section 5 provides that the capital stock shall be increased and may be decreased under the conditions therein mentioned. of Sections5^ 6 and Succeeding provisions however, make it clear that may is here used in the sense of shall, as applied to cases aris- VJk w 1017 ing under (a), (b) and (c). It seems reasonable to infer that it is used in the same sense as applied to (d). But whether so used or used in its more literal sens® is here inmaterial, for so far as the answer to the question submitted is concerned; the result is the same whether the Board is required or merely authorized to reduce the capital when member banks cease to be membe rs. Nor can any significance be attached to the fact ■that specific provision is made for reducing the capi4 tal stook of a Federal reserve bank in cases arising under (a), (b) and (c), while the Aot is silent as to cases arising under (d). The cases specifically pro vided for include cases where the member banks cease to be members as. the direct result of their own acts or conduct, Cases under (d) arise where banks cease to be members as an incident of the exercise of the power of the Federal Reserve Board to readjust districts. The grant of the specific power to readjust carries with it, as fully as if expressed in the Act, the power to do what is.necessarily incidental. ed«, 505j (Broomfs Maxims; 7th I9d U. S, 12.) My conclusion as to the second question submitted is that the Federal Reserve Act, in prescribing a mini mum capitalization of $4,000,000 for Federal reserve banka as a condition precedent to commencing business, does not require that such minimum capitalization shall be preserved under the circumstances. Very respectfully, T. W. GREGORY. Attorney General, Tho President, The White House. 4/15/16 W. P. G. HARDING. GOVERNOR PAUL M. WARBURG. VICE GOVERNOR FREDERIC A. DELANO ADOLPH C. M ILLER CHARLES S. HAMLIN E x -O f f i c i o m e m b e r s W ILLIAM G. McADOC SECRETARY OF THE TREASURY CHAIRMAN JOHN SKELTON W ILLIAM S COMPTROLLER OF THE CURRENCY H. PARKER W ILLIS . SECRETARY SHERMAN P. ALLE N . ASST. SECRETARY a n d F is c a l a g e n t FEDERAL RESERVE B O A R D WASHINGTON REPLY TO FEDERAL RESERVE BOARD A p r il 15j 1916* SIR: About a year ago the Federal Reserve Board forwarded to each Federal Reserve Bank a form of stock certificate with the suggestion that though each hank could properly have its own certificates prepared in any form it desired nevertheless it might he advisable for the various reserve banks to issue uniform stock certificates to their member banks. The whole question was subsequently postponed when the Bureau of Internal Revenue ruled that stock certificates of Federal reserve banks would be subject to the War Revenue stamp tax. In view of the fact that the Attorney General has since filed an opinion to the effect that Federal reserve bank stock certif icates are exempt from the stamp tax,, the Board has caused the Bureau of Engraving and Printing to prepare a design of stock certificate, the body of which is substantially similar to that submitted a year ago. Slight changes in wording and arrange ment have been made in accordance with various suggestions. The Bureau of Engraving and Printing has made an esti mate of $1,017.53 for "the engraving of 24,000 of these certifi cates bound in bock form,'of 503 each, with stubs attached. On the basis of an order aggregating 24,000 certificates each Fed eral Reserve Bank can obtain 2,000 certificates for $84-50- The plate once engraved, future orders will undoubtedly be at even a less figure. The enclosed copy has been prepared by Counsel after a careful consideration of the various suggestions made to the Board and in substance represents the concensus of vie1,vs express ed by the several Federal Reserve Banks and members of the Board. Because of the desirability of haang all certificates alike it is hoped that you may see fit to adopt this form for your bank though there is, of course, no obligation upon you to do so. If satisfactory, please advise the Board as soon as possible of the number of certificates desired so that the plate may be engraved at once. Respectfully, Assistant Secretary. 6 1 8 . MEMORANDUM OF THE GENERAL PRINCIPLES TO BE FOLLCTSED IN THE PREPARATION OF A CHECK CLEAR ING AND COLLECTION PLANWashington, D. C. April 17, 1916* Introductory The Federal Reserve Board has no plan and has no wish to suggest to the Governors of the Besiks any specific "Plan". It considers that this is a problem for the Executive Officers of the Federal Reserve Banks to work out* However, m working out their plan, the Governors should been: in mind and adhere to the following general propositions: First; It is to be noted that by May 16, 1917, a large part of the National bank reserves will have been transferred, and that by November, 1917* the final transfers will have been made* By that date, at the latest, each Federal Reserve Bank must be in readiness to render for its member banks the service of check clearing and collection* This, however, does not mean that any Federal Reserve Bank is expected or required to ren der this service without charge or for less than cost* Seconds While the opinion of the Attorney General has not yet been rendered, informal talks with memberb of his Staff seem to indicate that that office regards the language of Section 16 of the Act, m which the following phrase is used: 1020 -2 - —618— i "Every Federal Reserve Bank shall receive on deposit at par from member banks or from Fed eral Reserve Banks, checks and drafts drawn upon any of its depositors, " as meaning that these checks must be credited upon receipt, at full face valut,. It docs '‘ot necessarily folio v, however, that Federal Reserve Banks would permit items thus credited to be drawn against until collections had been made, and if they did permit their being drawn against in anticipation of collection, that they would not be fully entitled to charge the cost of collection, interest on the funds advanced, etc. Third: It is expected that every Federal Reserve 3ank will approach this sub]ect from a purely practical, rather than a theoretical standpoint and will, so far as prac ticable, adhere strictly to the banking practices which the last fifty years have developed. The Federal Reserve Board has no desire to compel member banks to do their check clearing and collection through the Foderal Re serve Banks, but it does expect the Federal Reserve Banks to offer this service to their member banks on substantially as favorable terms as the larger banks of the big cities, heretofore acting as reserve agents for their country bank clients. A system of chock clear ing whicn might be perfectly satisfactory m theory, but under which no business /oula be deno, could hardly be considered as a satisfactory solution of the problem. 1021 618. -3- Fourth: It follows from the foregoing that the Board does not contemplate the adoption of a plan which 3hall he mandatory or compulsory upon the member banks of the Federal Reserve System. The Board will, however., require each Federal Reserve Bank to establish, .within the near future, for such .of its member banks as desire to avail themselves cf it; a system of check closuring and collection at least comparable with that in general use in the country; that is shall analyze carefully the cost of its service and charge these members the actual cost of the servico rendered &2Q Washington, D. C., March 15, 1916• I must apologize for not 'sooner having answered your letter con taining the clipping from the Boston Transcript by Mr. Arthur Stanwood Pier, entitled "Wilson*3 Muzzle for Americans,11 and in this tardy reply I shall endeavor to eliminate all personal feelings and devote myself to the nation al aspects of the matter. Mr. Pier is evidently deeply offended because the United States will not give up its time honored position of neutrality and intervene in the war now going on between the great powers of Europe. He seems to think that it was the duty of the United States to protest when Belgium was entered by Germany, and that if we were fulfilling our duty we would new be at war with Germany, joining the Allies. So far as the violation of Belgium neutrality goes, it would be sufficient te say that Germany did not violate the Hague Convention when it entered Belgium, for prior to entry it delivered an ultimatum tc Belgium equivalent to a declaration of war. This fulfilled, absolutely, all re quirements laid down by the Hague Convention. Germany, however, did violate the treaty of 1839 which Prussia signed with Austria, Russia, England and Prance, and which provided for the neutralization of Belgium. The United States, however, was not a party to this treaty, and,, there fore, it could not, consistent with neutrality, protest against its viola tion. To have protested would have been equivalent to giving up neutrality and siding with the Allies. X am aware that Senator Root, in his recent speech in Hew York, and Ex-President Roosevelt, have both recently contended that the United States should have protested because ef the alleged violation tf the Hague Cinventien. In answer te this, however, it is sufficient tj point out that Senator Root was in the Senate when Germany entered Belgium, and, sd far as l know, never protested or never introduced any resolution of protest ner did any other member of the Senate or the House. Furthermore, shortly after this entry, Ex-President Roosevelt, in public interviews and in a magazine article, made it perfectly clear that he did not believe that the 1023 United States should protest against this action of Germany. For example, four days after the invasion of Belgium, in a speech in ®ew York, he stated that "we should be thankful beyond measure because we are Americans and not at ■war." He further urged support of the Administration in securing peace and justice. He said nothing of any duty to Belgium. Again, at Hartford, Conn., on August 15, 1914, he discussed the Bryan peace treatiesbut said nothing about any ebligation under the Hague treaties. Again, seven weeks after the Belgium invasion, he printed, in the Outlook, on September 25, 1914, an elaborate article on the war, with long discussions of this Belgium phase. In this article he states that there is even a possible question whether we are not, ourselves, like other neu tral powers, violating obligations which we have explicitly or implicitly assumed in the Hague treaties, but adds that, under actual conditions this Hague guarantee would excite laughter were not the tragedy such as to move us to tears instead. In another part of the article, however, he deals directly with the question of our duty to intervene because of the German invasion of Belgium. Here is what he says: '•A deputation of Belgians has arrived in this country to invote our assistance in the time of their direful need. What action our Government can or will take, I know not. It has been announced that no action can be taken that will interfere with our entire neutrality. It is certainly eminently desirable that we should remain entirely neutral, and nothing but urgent need would warrant breaking our neutrality and taking sides one way or the other.* * * Of course, it would be folly to jump into the gulf our selves to no good purpose, and very probably nothing we could have done would have helped Belgium. We have not the smallest responsibility for what has befallen her, and I am sure that the sympathy of this country for the suffering of the men, women and children of Belgium is very real. nevertheless this synpathy is compatible with full ack nowledgment of the unwisdom of uttering a single word of official pKitest unless we are prepared to make that protest effective; and only the dearest and most urgent national duty would ever justify us in deviating from our rule of neutrality and nontoterferenee.* Furthermore, Ex-President Taft, in a speech at Morristown, H. J., publicly expressed his full concurrence in the attitude of President Wilson 1024 620 -3*» Even, hovrever, if the Hague- Convention had teen violated, it would hate imposed no duty on any. nation which had signed the treaty to protest unless its interests were injured by the act. For example, none of the signers of the Hague Convention protested when Austria-Hungary assumed sovereignty over Bosnia and Herzogovina in 1908, nor did any of them protest when Italy siezed Tripoli in 1911. Nor did the British Government protest because of any violation of the Hague Convention of 190?, for it had never ratified it; its protest and action were based upon the violation of the treaty of 1839, to which, as I have said, the United States was not a party. I may add, also, that if the United States was bound to protest at the Belgium invasion, it was equally bound to protest at the invasion of Luxemburg by Germany, for Luxemburg also was neutralized by the treaty of London in 1867, to which Prussia, and the other nations now at war were parties. I think, on reflection, you will see what a position the Presi dent of the United States would have been in if, as the official head of one hundred million people, without any action on the part of Congress, he had protested to Germany* Supposing Germany replied that we were not affected and that, in short, it was none of our business* The President then would have had to back up that protest with force, which he could not do without the authority of Congress, and which we could not possibly do because of our unpreparedness, even if Congress had advocated such a course. Can you not see what a humiliating position this would have placed the United States in? President Wilson, however, soon after the outbreak of the war, offered his services as a mediator, - the Hague Convention providing that such an offer should not be considered an unfriendly act, - but neither party availed itself of this offer. Our country has always proceeded on the theory of keeping out of to Europe, you must keep your hands off the New World, and then follows the necessary corollary * we must keep our hands off of Europe unless we are directly injured by the act of some belligerent. This is well brought 620 -4 - out in the declaration attached by the Unitea States Senate t» m e of the most important Hague Convention treaties. This declaration read as follows; "Nothing contained in this convention shall be so con strued as to require the United States of America to depart from its traditional policy of not intruding upon, inter fering with or entangling itself in the political questions of policy of any foreign State; n«r shall anything contained in the said convention be construed to imply a relinquishment by the United States of its traditional attitude toward purely American questions." This would seem to be a clear and explicit statement of the policy of the United States. It has bound us in the past and I trust it will always be our rule of action in the future. If by protesting we were drawn into the war on the side of the Allies, against Germany, it would not only violate the established policy of the United States, but it would lay the foundation for a repudiation by foreign nations of the ilonroe Doctrine. A nation can observe neutrality only when its Government treats all belligerents alike. That has been President Wilson's endeavor throughout, and that attitude naturally prevented the Government of the United States, as it has prevented that of Spain, Switzerland, Holland, Denmark, Norway, Sweden, and the iatin-American Republics, from making any official protest or interfering in any way in this unfortunate war. Whenever Germany has injured the United States, or its people, by a violation of International Law, President Wilson has been quick to demand redress. How far he has been helped by Congress in this atti tude you can gather from recent events in that body. In any event, I think you will agree with me that the President has no right; by any official act, te put the United States in any other p*sitisn than that of a strict neutral, without the direct authority of Congress, in which body is vested the right to declare war, and a violation of neutrality under these circumstances would be equivalent to a declaration of war. Mr. Pier also claims, in his article, that President Wilson should have protested against the atrocities in Belgium. It would seem, hswever, to be clear that no President, or country, should over protest 1025 ,1026 020 5- against actions in any foreign country without f i r s t making1an independ ent investigation for itself by sending a com m ission, or otherwise} for however clear the atrocities may seem, it.should never he forgotten that evidence should be taken on both sides of the controversy before any action is taken. Por example, President Cleveland notified the British Government that its acts in Venezuela were in violation of the Monroe Doctrine, but he was careful to state that he should appoint an inde pendent commission to investigate the whole matter and report, and that then he should sustain the report of said commission with all the authority *f the United States. There seems to be a feeling that President Wilson has, by failing to protest against the atrocities in Belgium, in some way changed the traditional policy of the United States. It would seem t* be a sufficient answer to this to point out that between 1901 and 1909 when Mr. Roosevelt was President, and, during the greater part of which time, Mr. Soot was in the cabinet, there occurred various atrocities abroad. Por example, in 1903 occurred the terrible massacre at Kishineff. At the same time Macedonia was running red with blood; in 1905 the horrors of the Congo were revealed. In the same year Korea was absorbed by Japan, although the United States had entered into a treaty with Korea promising to use its best efforts in case Korea was unjustly treated by any power. Ex-Presi dent Roosevelt, in the Outlook for September 25, 1914, among ether things, writes the following with Regard to Korea: •’Korea is absolutely Jaxoan’s. To be sure, by treaty it was solemnly covenanted that Korea should remain independent. But Korea was itself helpless to enforce the treaty, and it was out of the question to suppose that any other nation with no interest of its swn at stake would attempt to do for the Koreans what they were utterly unable to do for themselves. Moreover, the treaty rested on the false assumption that Korea could govern herself well. It had already been shown that she could not in any real sense govern herself at all. Japan could not afford to see Korea in the hands of a great foreign pswer. She regarded tyer duty to her children and her children's children as overriding her treaty obligations. Therefore, when Japan thought the right time had come, it calmly tore up the treaty and took Korea, with the polite and businesslike efficiency it had already shown in dealing with Russia, and was afterwards to show in dealing with Germany. The treaty, 620 1037 -6 - ■when tested, proved as utterly worthless as our own recent all-inclusive arbitration treaties - and worthlessness can go no further#” In 1906 Morocco was parceled out, and in the sane year occurred the terrible Russian massacre. In 1909 wo had the Armenian horrors. All of these terrible events occurred during Republican Admin istrations, yet, to my knowledge, no official protest was ever made, either by the President or by Congress. May I also point out to those claiming that the unwarranted death of a single American demands an immediate declaration of war, that President Grant, in the Virginius case, accepted an indemnity from Spain for the brutal murder, without trial, of a large number of Americans In Cuba. Mr. Pier, in his article, makes the surprising statement that chivalrous feeling caused the United States to take sides with the Cuban revolutionists. Even a limited knowledge of history would be sufficient to satisfy anyone that the United States interfered in Cuba primarily for the reason that its own interests were deeply affeoted by the terri ble conditions in that island. Cuba is within the sphere of influence •f the United States, and, furthermore, eur citizens were deeply affected by the incidents there. In this connection let me say that I have recently read a pamphlet prepared by Sr. Morton Prince, wh* severely criticises President Wilson for not protesting against the German entry into Belgium, and citing the faot that President Monroo, in a message in 1821, expressed the hepe that the Greeks, who were then struggling with the Turks for independence, might be successful. Dr. Prir.ce also cites the fact that Daniel Webster, at that time in the House of Representatives, made a strong speech in behalf of Greek independence. It is a faot that President Monroe, in one of his annual i messages, expressed the personal hope that the Greeks would succeed, but no resolution was passed in Congress or the slightest assistance given to the Greeks in their valient fight. It is true that Daniel Webster introduced a resolution providing for sending a commission to Greece to 1088 620 investigate conditions, and that he, in a strong speech upon this reso lution, expressed the deepest sympathy with the Greeks. It is a fact, however, that Mr. Webster never asked for a vote on this resolution; on the contrary, he expressly asked that it be laid on the table. He intro duced it merely as a basis for a speech, and, as a fact, as I have stated, no expression of sympathy or aid to Greece was given by Congress. Ur. Webster's feeling as to the duty of the United States to maintain neutrality can be vrell illustrated in another case; that of the Hungarian rebellion in 1850. Yon will remember that Kvssuth had fled to Turkey, and that he was brought to America on a United States warship. He was received everywhere with acclamation, and every attention was paid to him personally, but Congress passed no resolution of sympathy, nor did it aid him in the slightest degree in his efforts. On the contrary, the President told Kossuth that he could do nothing for him. Web3ter and Clay told him the same, which made him deeply indignant. Mr. Webster, in writing about this, said to a friend that if Kossuth should speak to him of the policy of intervention "I shall have ears more deaf than adders". In conclusion, let me say that, so far as I can find, our Govern ment has never protested at the conduct of nations abroad engaged in war when that conduct did not directly injure us. neutrality. Our policy has been that of We demand that foreign nations shall keep their hands off of »ur continent, and, as I have said, the necessary corollary of this is that we must keep out of interference with their affairs. This has been the policy laid down by Washington, Jefferson, Adams, Ilonrne, and by every other President of the United States, including President Wilson, and I must ex press the firm conviction that it will prove an unhappy day for the United States if ever we shall reverse that policy. -1 Very sincerely yours, -ft f ) 0 0 i ' :- v i ' r ' W 622 THE BANKER AND THE PUBLIC Address of M ILTON C. ELLIOTT To be delivered at meeting of Texas Bankers Association at Houston, Texas - May the 2d. -OoO- MR. PRESIDENT AND MEMBERS OF THE TEXAS BANKERS ASSOCIATION: One of the incidental benefits that may be said to have re sulted from the passage of the Federal Reserve Act is that it has awakened both the banker and the public to a realization of the true relations that exist between them. The banker in studying the whys and wherefores of this legislation has necessarily viewed the subject Of banking from a broader and more comprehensive Standpoint and has appreciated more fully than ever the public responsibility that he assumes when he undertakes the management of a bank. The public has been awakened to a realization of the vitally important part that banking plays in the commercial life of the nation. In recent years there has been a tendency to look upon banks as purely private corporations organized for individual prof it, and under what we have called our banking system the right to start a bank has been regarded as an inherent right of every citi zen. To challenge the right of any set of men to charter a bank if they can provide or procure the necessary capital would prob ably be regarded as unreasonable as to challenge the right of the same individuals to charter a corporation to manufacture shoes. When we turn back the pages of history, however, we find that in their inception the incorporation of banking institutions c ‘^ '-I TbAfl 622 -2was looked upon with fear and suspicion. The States were reluctant to grant charters and those that were granted contained exacting restrictions. The right of the Federal Government to incorporate a bank was the subject of litigation and bitter controversy for a number of years. The great State of Texas, as you will no doubt recall, came into the Union with a provision in its Constitution -"That no corporate body shall hereafter be cre ated, renewed, or extended with banking or discount ing privileges * * * The legislature shall prohibit by law individuals from issuing bills, checks, promissory notes, or other paper to circulate as money." As you know, it was not until 1903 that the legislature of Texas provided for the submission to popular vote of an amendment to the Constitution authorizing the incorporation of banks. This amendment was adopted in November, 1904, and in 1905 a general banking law was enacted Under which banks might be incorporated. It seems that as late as 1852 there were no banks in Florida, Texas, Arkansas, Illinois, Wisconsin, Iowa, Minnesota, Oregon, California, and the District of Columbia. One conception of banking advocated in the early days ap pears to have been that it should be conducted solely for the bene fit of the public; that the profits from this business, like the revenue derived from taxation or from the collection of duties on imports, should be paid into the public treasury for the benefit of the people. In the History of Banking in the United States by the late professor Sumner of Yale, he says, in speaking of the early banking i n s t it u t i o n s "We observe that a bank was conceived of primarily as a means of creating wealth. Every one wanted to share in its beneficent operation. If the legislature created it, all the people ought to participate in its blessings." Later in discussing the debates in Congress on the sub ject of renewal of the charter of the first Bank of the United States which expired in 1811, he says that "Nicholas of Virginia moved that 'provision' be made by law for a general national establishment of banks throughout the United States, and that the profits arising from the same, together with such surpluses of revenue as may accrue, be appropriated for the general welfare, in the construction of public roads and canals, and the es tablishment of seminaries for education throughout the United States 1." When we contrast the attitude of the public in these early days with that of the present time, it is obvious that the pendu lum has swung to the other extreme, and that the private interest of the stockholder or owner often overshadows the public £oapof*3ibility that is involved in the management of a bank. While the incorporators may take into consideration the needs of a community before undertaking to open a new bank, this is frequently a matter of business judgment from the standpoint of the prospective owner or stockholder. The State or Federal authori ties may likewise make an investigation of the local banking facili ties before granting a charter to a new bank, but here again the question to be determined is primarily whether the community can support another bank. When the charter has been obtained and a bank is opened for business other considerations than that of the service .a r\n>c% 622. - U - to be rendered to the public are at times regarded as of first im portance* 0ompetition with other banking associations naturally be comes an important factor* While this competition is no doubt de sirable in so far as it encourages the officers and directors to build up and strengthen a bank,, it becomes a dangerous element when these officers and directors lose sight of their public responsibility and view the success or failure of the bank solely from the stand point of the amount of dividends that may be earned, or when they fall into the popular fallacy of judging the strength of a bank solely from its aice as indicated by its balance sheet. It is, of course, true that a bankTs earnings and the volume of its resources are both important elements in determining its success, Whether we view the subject from the standpoint of the public or from that of the share holder. It is, however, the source of its earnings in which the public is interested and the causes <£ the increase of its deposits. A bank may increase its earnings by speculative investments or by charging excessive rates of interest on doubtful risks. It may purchase deposits by paying a greater rate of interest than its busi ness justifies. It may exceed its corporate powers but by the transaction may net a profit. In any of these cases its statement of condition may indicate success if we are to judge by the appar ent results obtained. It is obvious, however, that a bank with good luck may increase both its earnings and its resources but may be operated without consideration of its public responsibility. •a ^ «i 1 ,yo. > 622 -5 - It is true that such instances are rare and yet we hot infrequently hear bankers say that the administrative officers of the Government should limit their inquiries to the financial condi tion of the bank,, and if it is solvent and its Capital is unim paired, it constitutes an illegal assumption of authority for an administrative officer to inquire into those operations which brought about improvement in its financial condition. When we analyze the business of banking, however, is it not true that the public has a very vital interest in each and every operation? And is not the assumption that banks are purely private corporations organized for the individual profit of the shareholder just as extreme a view as the early conception that the profits arising from this business should be paid into the public treasury? And is it not true that all administrative officers must.take into consideration the public responsibility of banks and bankers when they are called upon to make rulings as to the operations of the banks? I, of course, do not mean to suggest that bankers, as a general rule, look upon their institutions as organized solely for the profit of the shareholders. On the contrary, there is an increasing tendency on the part of the officers and direct ors of banks to consider general and not merely local condi tions in the conduct of the banking business. Bankers are brought into such close and intimate contact with all commercial and in dustrial activities they are naturally alive to the interest of their communities. They must constantly study general conditions in '_ 622 -6order to anticipate the needs of the public. There are perhaps no set of men who have occasion to consider and do consider the public welfare as extensively as the officers and directors of our bank-4 ing institutions. The public.* however, has an interest in each in dividual operation of a bank as well as in the net result of these operations, and it is this fact that is sometimes lost sight of. The comparatively few adverse criticisms of the Federal Reserve Act appear to be based primarily upon objections which in dicate that those indulging in criticism have considered the private and not the public character of the tanking business. For example, among the important provisions of the Act are those which relate to the collection an<f clearance of checks, and which authorize Fed eral reserve banks and the Federal Reserve Board to perform the func tions of clearing houses. There is perhaps no Operation of the bank ing business which better illustrates the public responsibilities assumed than that which the banker undertakes when he performs the service of collecting checks and other items payable elsewhere than at the counters of the bank. Viewing the matter from the standpoint of public service it would seem that if the efficiency of this service can be increased by the adoption of a more direct and scientific method of handling these items, such a method should be welcomed, by the banker; and yet it appears that one of the principle objections urged against the. sys tem provided by the Federal Reserve Act is that the bankers are afraid the operations‘of this system will curtail their earnings from collection and exchange charges. Assuming this to be true, K.0 1" is not the objection based upon the assumption that the shareholders are entitled to receive these charges for the service performed, whether or not this service can be rendered by more direct methods on a basis which would benefit the public ? Is it not true that this objection is based upon the fact, that a clear conflict results between the interest of the shareholder and the interest of the general public. It is not my purpose to undertake to discuss in detail the intricate operations that are involved in our present system of check collections and clearances, but as bearing upon the question of the bank's responsibility in these matters and of its duty to the public there are certain elementary principles involved, a discussion of which may serve to illustrate the necessity for the perfection of a more scientific system. Various experts are at work on plans de signed to precipitate what they call the "float"; that is to say, to reduce the number and volume of items that are constantly in transit. These experts may not be agreed as to the details of op eration which will best accomplish this purpose, but they apparently are agreed as to the necessity for improving this service by the adoption of more scientific methods. They are also more or less agreed that any system must have the cooperation of the banker in order to reach its greatest efficiency, and from the layman's stand point it seems obvious that defects which are known to exist should be corrected, and that the correction of such defects should be brought about by the cooperation of the bankera rather than by corrective legislation. O/ni JUAif.) $22 -8In discussing the principles involved, my excuse for refer ring to certain elementary factors before an audience of this kind is that all banking operations are so closely inter-related it is difficult to discuss any:one operation without considering the funda mental though well-known principles that are involved in that particular operation. Under the Act of March lU, 1900, which amended Section 5211 Re vised Statutes of the United States the gold dollar is established as the standard unit of value and all forms of money issued or coined by the United States must be maintained at a parity of value with this standard. The silver dollar, fractional and minor coins are made legal tender by statute within certain limitations and certain notes of the United States are likewise made legal tender. The volume of this form of % . currency or money, however, is, of course, inadequate to carry on the enormous commercial business of the United States, and bank cred it as a medium of exchange takes the place of money in a very large proportion of our commercial business, As the test writers express it "A bank has been aptly defined as a manufactory of credit and a machine for facilitating exchanges. It manufactures credit by accepting the business prospects of its customers as security in exchange for its own bank credit in the form of a deposit account. Business credit cannot be conveniently used for current business transac tions, but bank credit in the form of checks and drafts is widely acceptable and is the actual medium of exchange for a large part of the community." While a great many obligations are discharged by the use of checks and by an exchange of credits this is due to the fact that the public voluntarily and not by reason of any legal requirement f, fs*y*y 622 -9accepts these checks, and through an exchange of credits many obligations are canceled without the actual use of money. The public is willing to utilize bank credit in this way, because it furnishes a convenient method of handling commercial transactions and because it has confidence in the ability of the banks to pay these checks in legal tender whenever they are called upon to do so. It would seem to follow that any system of check, clear ances and check collections which strengthens the ability of the banks to respond to a larger percentage of demands for legal tender re sults in a benefit to the bank by adding to the practical value of this medium of exchange. Under our present system the 25^000 or more banks in the United States act more or less independently; each bank selects its own correspondents and makes its collections primarily through these correspondents. For example a customer in Dallas presents a check for $1,000 drawn on a San Francisco bank. The Dallas bank, not having a correspondent in San Francisco, indorses and forwards this check to its correspondent in New York. The New York bank credits Dallas and forwa.rds the check to Chicago. The Chicago bank, in turn, forwards it to Denver and the Denver bank to San Francisco. Until this check is actually paid in San Francisco the Dallas bank remains liable upon it as indorser. It is true that it has obtained a credit in New York, but if the check is returned this credit will be canceled. In the meantime, it has paid out ±0? B 622 -10- funds representing the face value of the check to the payee, and if it is returned unpaid, the hank must look to the payee or drawer for indemnity. When we multiply this transaction by the number of items received by the 25,000 or more banks in the United States, and when we consider that each bank receiving an item for collection is likely to select one of its correspondents through which to sentl it, it is manifest that bank collections are not made through defined chan nels and that the time consumed in making a collection varies accord ing to the route by which the several items happen to be sent. As a consequence, a very large number of items representing a very large volume of money are constantly in transit. In the meantime the bank which receives these items on deposit and forwards them for collection is under obligation to pay the amount they represent in legal tender if it is called upon to do so. If, by a more scientif ic handling of these collections, the amount in transit can be re duced and the time consumed in collection can be cut down, the banks to this extent are given a greater ability to respond to the demands that are made and this increased ability is a matter of interest to the public. While the check performs a vitally important function in our commercial development and while it is estimated by some au thorities that approximately 90 $ of our commercial transactions are carried on by its use, we must not overlook the fact, that this use is made possible by the voluntary act of the public and not by statute. 622 -11- I do not mean to question the soundness of the practice. The experience of nearly all nations has demonstrated the fact that real commercial development is made possible only through the scien tific use and exchange Of credits. Some economists go so far as to claim that if a proper system of credit exchange can be worked out there is no need for a metallic currency. Whether this view is extreme or not every factor which contributes to the ability of the bank which is used as a medium of exchange,, to respond imme diately to demands made upon it, strengthens the system and makes more valuable the credit used. Bank clearances may be said to constitute the most direct method of exchange of credits as between banks* It is through this method that reciprocal balances are offset or canceled. Heretofore clearing house operations have been confined to the larger cities. If the banks in one city find that time can be saved by meeting at one place and exchanging reciprocal items rather than by having each bank send out by runner the checks drawn against every other bank in that city, is it not reasonable to assume that the same re sult may be obtained as between banks in the same general locality? And is not the plan provided for in the Federal Reserve Act merely the application of a plan which has been tried and used successfully in the larger cities? There can be no doubt of the fact that, as we increase the number of banks that clear through any clearing house, we will decrease the number of items that are in transit and will reduce the time consumed in making the exchange of credits. 622 -1 2 - When Congressman Glass, chairman of the Banking and Currency Committee, made his report to the House, he voiced the hopes of the framers of the Federal Reserve Act when he said, in speaking of hank clearances and collections "The provision as it stands will result in an immense saving to the trades people of the United States. It will eliminate the amazing wastefulness incident to the many independent collection organizations hy substi tuting one compact collection system." It cannot he denied that the Act provides for a more scien tific handling of this important function of the banking business. By cleaning the various items received for collection through the agency of the twelve Federal reserve banks, the element of time will be materially reduced. For example, an item on San Francisco will not have to go through four or five intermediary banks, but may go direct from the Federal Reserve Bank of Dallas to the Fed eral Reserve Bank of San Francisco, and through an adjustment of accounts in Washington the transaction will be completed in a very much shorter time than is possible through the many independent col lection organizations now in use. The advantages of one compact system are obvious. The objections that are raised are founded primarily on local inter ests. A bank may prefer to send an item for collection to its reserve correspondent, since it shows immediately a credit with its correspondent, and not only counts this as part of the reserve which it is required by law to maintain but in many instances receives interest on this deposit, In counting as reserve an item which fVl s Jw'J 312 . k 622 -13is drawn against some other hank than its reserve agent, it is treating a conditional credit as funds actually deposited with its reserve agent* In other words, let us suppose that a Dallas bank sends a check on San Francisco to its New York correspondent, which is its reserve agent and receives credit on the books of its reserve agent. If the check is returned unpaid, it is charged back to the account of the Dallas bank, and until actually collected the Dallas bank remains liable on this check. It does not show this liability on its books, but takes credit for the amount of the check. is one of the legal inconsistencies of this practice. This When the Dal las bank receives this check and gives credit to the depositor it has a claim only against the drawer and indorsers of this check. The San Francisco bank, not having certified the check, ha 3 assumed no liability. If, instead of receiving a check from its depositor, it accepted his promissory note and indorsed and rediscounted this note with its reserve agent, while it might show the credit thus established as part of its reserve, it would show on the other side, of its ledger a liability to its reserve agent for money borrowed in addition to the liability shown on the individual ledger to the depositor. The practice, therefore, of building up reserves by condi tional credits presents an anomalous situation, and if banks should be required to discontinue this practice and should not be permitted to count collection items as reserve, until they have been actual ly collected, they would manifestly take into consideration the -f! f\ 622 -lU- element of time and would undertake to reduce this to a minimum by the adoption of any scientific method of clearancest It is, of course, realized that a change of this sort must be brought about gradually and the Federal Reserve Act pro* vides a medium by which this can be done without disturbance to existing conditions. It would seem to be to the interest of the banks to adjust their operations so as to accomplish this purpose. In the same manner it is to their interest to bring about by thorough cooperation the perfection in every detail of a scien tific system of banking. This is of especial importance at this time in view of the general disturbance of international trade conditions that re sults from the great European war. No bank could be expected to liquidate its own assets in time to discharge any large proportion of its obligations in case of unusual demands if it had to rely solely upon its own debtors. The very nature of the banking business makes this impossible. The larger proportion of its loans and investments are made for fixed periods of time, while the larger proportion of its obligations are payable on demand. When these demands are in excess of normal and when the bank is under the necessity of converting its loans or in vestments into cash in order to meet these demands, it must rely primarily on other banking institutions. When unusual demands are made upon a great number of banks, it necessarily becomes more difficult for the banks to convert their O, i 622 -15investments into cash. The panic of 1907 is still sufficiently fresh in the mem ory of the hanker for this situation to he fully understood and ap preciated. the experience of that year demonstrated the fact that when the strain becomes general liquidation of assets becomes cor respondingly difficult. You will recall that at that time the hanks were forced to resort to various expedients in order to meet the demands made upon them. United States bonds were borrowed in order to increase circulation. In .many localities banks found it neces sary to refuse to pay out money except in small amounts. house certificates were used as a temporary substitute. Clearing Banks which had money on deposit with their reserve agents found it difficult to obtain this money for their needs since their reserve agents were likewise in need of additional funds. Banks in reserve cities which had been competing for country bank accounts began to question the advisability of soliciting and paying interest on those deposits. The Federal Reserve Act provides a scientific remedy for the difficulties that were experienced during that year. One of its purposes is to make the reserve carried with a Federal reserve bank actual reserve which will be available when needed and not merely reserve in name. By a concentration of a part of the cash resources in the twelve Federal reserve banks funds are made availdie for use wherever they are needed. If the demands of one sec tion are greater than the demands of another, the Federal reserve bank may obtain rediscounts with other Federal reserve banks, and J'Jj —1 6 - 622 may thus acquire the benefit of the surplus funds in other districts* In addition to making the money in circulation available whenever it is^need^d provision is made for an increase of circulation by the issuance of the Federal reserve note* The machinery has,, therefore, been provided for a compact and scientific system of banking which gives additional strength to every member bank. The critics of the system do not deny that it is scientific and sound, but complain that it is composed of only or 7,500 out of 25,000/more banks; that it does not represent the full force of our banking power. The advantages of the System, however, are fortunately open to the State banks and trust companies as well as to national banks, and it is possible for the State institutions to share in its benefits. Bankers and economists are not agreed as to the effect that the European war is destined to have on the commercial business of this country. There are those who feel that during the readjustment of commercial interests following the close of the war this country must look for a reaction and can not expect an indefinite continuance of the present prosperous conditions; that the markets of the bellig erent nations will be reopened, and that competition for the world’s trade will make it difficult for this country to market to advantage its great resources; that securities held by citizens of other coun tries will be sold and will have to be absorbed by our markets; that following a period of commercial prosperity it will be difficult for those who have shared in and enjoyed this prosperity to readjust them- 622 -17- selves to new conditions; that plants and factories which are now making munitions of war and which are supplying the "belligerent na tions with necessities will have their output reduced and will have to find other field for their activities. There are others who are inclined to the view that there will be no substantial reaction until sometime after the close of the war; that competitive markets will have to be reorganized; and that during the period of readjustment of the commercial affairs of those unfortunate nations which are now engaged in this great con flict, there will continue to be a great demand for our products; that many of our factories and institutions which are furnishing supplies to the belligerent nations are already operating on profits earned and are accumulating a surplus which will enable them to con vert these factories to other uses. The economists, however, are agreed that sooner or later we must face conmercial conditions which are unprecedented in the history of the world; that, as one of the great commercial nations of the world, we must bear our proportionate part of whatever strain there may be. It can hardly be denied that,any situation that may arise can best be met by a compact, effective banking system better than by on unorganized system of unrelated banks. The enormous banking power of the nation should be used to advantage. I do not mean to question the strength of our banking institutions. It is manifest that our banks are stronger today than at any time in the history of the nation, and that we have the re sources and the potential power to insure continued prosperity is ~p 3 r* J.lutlJl no doubt true, but the responsibility is very largely with the bankers to determine the degree of that prosperity. By coopera tion and proper organization and by a scientific use of these re sources a greater degree of prosperity will follow than will be possible if the individual interest of the banker is to over shadow his public responsibility. Those who believe in preparedness might well apply the principles involved to our banking situation. Whatever potential powers the banks may have acting independently, their efficiency will be increased by systematic organization. It is encouraging to note that the State authorities are acting in harmony; the State laws are being remodeled along scientific lines; that that the legislatures of most of the States have taken the necessary action to make it possible to perfect our banking system, and we have every reason to believe that we will ultimately have a bank ing. system that will make it possible to utilize the banking re sources of this country to far greater advantage than is possible at present. We have reason to hope and believe that whatever the outcome of this world struggle this country will be enabled not merely to insure its own prosperity, but to lend thp assistance that its size and importance demands in the readjustment of the world's trade and the rehabilitation of the world's prosperity. „« THE BANKER AND THE DAW. a Address of MILTON C. ELLIOTT to be delivered at meeting of Alabama Bankers' Association - held at Pensacola,, Florida, on April 29, 1916. Mr. President and members of the Alabama Bankers5 Association 2 The Federal Reserve System has been in operation for a period of about eighteen months. The Act which created this System has been in force since December 23, 1913. It is natural that legis lation of this importance should be the subject of both favorable and adverse criticism. From these criticisms we::are enabled to determine to some extent the attitude of the banker as well as that of the public. From its operation during a period of abnormal prosperity it is difficult if not impossible to judge of the efficiency of any banking system. It is in times of stress rather than in times of prosperity that the real test must come. An analysis of the adverse criticisms of the Act, however, will at least indicate what are supposed to be the defects in this legislation which must be corrected or which must be proven not to exisl by experience or by a better understanding of the principles involved. On the one hand it is claimed by a very large majority of those who have followed closely the operation of the System during its first year that it has inspired confidence;; that it is develop ing sounder and more scientific banking practices and that in prin ciple it is the most important constructive legislation that has ever been enacted by Congress, -5^ - 624 - 1 C?.8 -2' On the other hand, there are those who say that it is a banker*s law passed in the interest of the banker; that it may in crease the lending power and the earning capacity of the banks, but that it does not make it easier for the borrower to obtain loans; that interest rates are still as high as ever, and that the fanner, the merchant, and the general public have not been benefited. There are officers of member banks who claim that the Act imposes unnecessary restrictions and hardships on the banking busi ness; that the transfer of reserve balances to the Federal reserve banks deprives them of earnings they have heretofore enjoyed; and that, while their lending power may be increased, other features of the Act offset atty advantage that might be derived from this source* There are officers of non-member banks who are inherently opposed to the System On general principles and others who are pur suing a policy of watchful waiting and who desire a practical demon stration in dollars and cents of the advantages to be derived from membership before becoming stockholders in any Federal reserve bank. who There are still others/( while admitting that confidence has been inspired and possible panics have been avoided) claim that the same results might have been attained by other less complicated methods. One of the prominent New York publications recently contain6 (J-;an article claiming that the Aldrich-Vreeland Act providing for emergency currency would have accomplished all of the benefits that have been accomplished by the Federal Reserve Act. The Wall Street Journal in a recent issue published an •| f*!A Q -a - 1- 7 -6 3 4 -3- article in which the following statement appears: "The head of one of tho largest hanks in the country privately declared when the Federal Reserve Act was going through: •We are hot much concerned^ we are gradually clipping cur bondsj the state laws are being retobdeled upon safe, conservative! lines, and my own impression is that it is only a question of time when the national banking system is a thing of the past and the Federal Reserve System will be on the hands of the Government and not on the hands of the banks* We can get along without any national banking system in the United States if we only have strong central reserve banks under state laws. 1 " I do not mean to suggest that bankers generally have made objections of this sort or that these criticisms represent the views of the majority. On the contrary the Federal Reserve Board and the officers of the several Federal reserve banks have had the coopera tion and assistance of the bankers in placing tho System in opera tion, and one of the most significant indications that the princi ples of the Act are both sound and scientific is the absence of any general complaint on the part of those who are most familiar with banking from a practical standpoint. The criticisms 'which have been made may be said to rep resent four viewpoints: (l) That of the borrower who assumes that to increase the bank's lending power correspondingly decreases the difficulty of obtaining loans. This is, of course, true in the sense that an increase of lending power makes available additional funds for conservative in vestment. It was not intended,however, to make it easier to borrow ■% rv~,r JLO «-*"*- Gzk - U - money without the same security or financial responsibility that was required before the Act. The bank is naturally as anxious to lend as the borrower is to obtain loans where the security or finan cial responsibility offered is adequate; Interest rates,, as a matter of fact, have been appreciably lowered in most sections during the past year. Whether this is due to the operations of the Federal reserve system or in part at least to an unusual period of prosperity, this criticism does not appear* to have been justified. In any event a charge of this kind can not be properly considered without the facts upon which it is based. (2) Another viewpoint to be considered is that of the officer of a member bank who feels that his bank is placed at a disadvantage in competition with non-member banks because of the requirements of the Act. To consider this and other like objections it is ne cessary to analyze some of the purposes and to consider some of the effects of the Act. (3) The third viewpoint may be said to be that of those who are inherently opposed to any Federal banking lasra and who feel that the States should have exclusive jurisdiction over and control of the banking business. This opposition has been mainfested from time to time ever since the adoption of the Federal constitution. A brief review of State and Federal legislation will best illustrate the difficulties involved in establishing a compact banking system where the banks composing, the system conduct their operation vender the laws of forty-eight States. These difficulties are manifest since a S ta te has j u r i s d i c t i o n over t r a n s a c t io n s c a r r ie d on w it h in ‘i t s "borders, while each bank is required as an incident of its business to engage in transactions outside of the borders of the State in which it is domiciled. (H) The fourth Viewpoint may be said to be that of the banker who recognizes the fact that the business of the country can be conducted to a greater advantage under a scientific banking system than it can be by several thousand unrelated banks, but who desires to be assured by a practical demonstration that the Federal Reserve System is scientific and will accomplish its desired purposes be fore he becomes a member of the System. Before undertaking to discuss the merits or demerits of the Federal Reserve Act, it seems appropriate to consider the attitude of the banker towards banking legislation generally. In addition to the Federal Reserve Act which was enacted by Congress, the various State legislatures in recent years have pro bably enacted more general banking laws than at any time during the previous history of this country. The trend of nearly all of this legislation has been to more clearly define and to provide for the regulation and supervision of the banking business. Has this legislation been enacted at the instance of the banker in order to safeguard and promote the banking business or has it been passed as a result of a popular demand for greater protection to depositors and customers of the banks? When we consider the fact, that there has been no popular outcry against abuses of banking powers; that there has been no concerted effort on the part of the public to correct supposed banking evils, io it not a significant fact, that the trend of - 6 - ..!IW State as well as Federal legislation has been to provide for a more effective supervision and regulation of the banking business? May we not infer from this fact that the banker feels that his interest as well as that of the public will be best served by the enforcement of laws which will require all banks to conduct their operations along conservative lines? It is unquestionably true that the officers of a bank rarely complain because of a too rigid examination of the affairs of the bank, but are much more apt to criticise a cursory and incomplete examination by a bank examiner. It was my experience as an ex aminer that the officers of banks were uniformly anxious to learn whether by inadvertence any provision of law had been violated, and to adjust their affairs ao as to conform to all requirements of the National Bank Act. The success with which the great banking business of this country has been conducted under an admittedly defective system is a sufficient proof of the conservatism and integrity of the banker. It is probably because he is lawabiding that he wants to digest any new or proposed legislation and to fully understand its purposes and probable effects. This being true, is it not reason able to infer that recent legislation providing for a more careful supervision and regulation of the banking business is attributable to the fact that such legislation strengthens the banks and promotes the development of the banking business along legitimate lines? Conceding this, it is necessary to consider what necessity exists J . ‘i 624 -7for legislation of the character which has been enacted by the States as well as by the Federal Government in recent years. This necessity can be best understood by reviewing briefly the history of legislation on the subject of banking in the United States. For many years banks were chartered by special acts of the legislature. It was not until .1838 that the free banking system was adopted by some of the States. of the earlier State In defining the corporate powers banks, various restrictions were imposed upon their operations. These restrictions related primarily to the amount I of indebtedness that might be contracted and to the character of in vestments to be made. Some of these restrictions were the outgrowth of the prejudice that existed against banking during the early period of our national history and furnish an interesting illustration of the extreme to which the legislature may go. The historians tell us that after the revolution the banking business was looked upon with fear and suspicion. a bank The granting of charter was almost invariably made a political issue which engendered the most bitter controversies. The first incorporated bank in the United States was chartered by the Continental Congress in 1781, and the validity of its charter was immediately brought in to question. It was contended that the Federal Government was without any power to incorporate a bank, and in view of the doubt created a charter was obtained from the State of Pennsylvania in 1782. This bank which was known as the: Bank of North America continued as a State bank until 1864 when it entered the national system. K f> -6P4- In 1791 the Bank cf the United States was incorporated by Congress. The right of Congress to create this bank was questioned and its establishment was bitterly opposed. a chdrter for a period of twenty years. It was finally granted Upon its expiration Congress after a bitter fight refused to renew its charter. In spite of repeated efforts on the part of those who were in favor of the establishment of another Bank of the United States it was not until 1816 that a charter was secured for the Second Bank of tho United States , ' This, bank which obtained a State charter before its federal charter expired was finally forced out of exist ence by political influencesi During this period it was almost equally difficult to obtain a State charter and those charters which wore granted contained many of the same restrictions that are now embodied in the National Bank Act and in the laws of the several States. In the "History of--Banking of All Nations", by the late professor Sumner of Yale, published by the Journal of Conmerce and the Commercial Bulletin in 1896, certain striking illustrations of the attitude of the public to banking are referred to. It is said that in 1803 two bank acts in Vermont wore vetoed on the ground " that banks demoralize the people by gambling and concentrate the wealth in the hands of the few and arc useless to the many since they give credit only to the rich. ” In speaking of the Bank of Alexandria,Virginia, it is said that,"It required all the eloquence of Brandt of Virginia to per suade the legislature that the little Bank of Alexandria would not - 9 624 - sweep away their liberties." It is said that in Massachusetts in 1799; "a law was passed making it unlawful to join any association to do hanking of any kind unless authorized by law, the penalty being $1,000.” As illustrating some of the restrictions imposed upon the banking business it is of interest that in 1874, the legislature of Rhode Island passed a law, "finitg any officer of a bank $50 for every check, note, or bill signed by him for less than $50 payable at any place out of the State. A fine of $5 was also imposed on any person who should pass a note for less than $5 issued by a bank out of the State ♦11 Among the early regulations which were adopted either in > the constitution of the banks or in the Acts of incorporation it is said that in the case of the Bank of Massachusetts, chartered Feb ruary 7; 1784, "amongst the rules of this bank were the full names of all delinquents to be posted in the bank in order to avoid use less applications for credit; absolutely no renewals." In a New York bank incorporated about the same time the constitution of which was supposed to have been written by Alexan der Hamilton, the following rule was said to have been adopted: "No discount will be made for longer than thirty days, nor will any note or bill be discounted to pay a former one. Payments must be made in bank notes or specie." Another interesting rule referred to which is in striking contrast with the publicity required in our banking business at ■f .O-fr er 621+ 1056 10 - this time was that of a hank in Hartford, which was that, "what passes in the hank not to he spoke on at any other place." In addition to these somewhat ex-theme and unusual fegulations many of the early charters contained JsrohihitiOns agaiftst making loans or dealing in real estate, they limited the amount of mofley that might he borrowed by a hank and stipulated certain investments which could not he made. Nearly all required the maintenance of a proper reserve against deposits and against circulation. A distinction was made between liabilities for deposits and liabilities incurred in other ways. It is claimed that this was due to the fact that deposits were created at that time hy the de livery of actual funds to the hank and were not multiplied as they are today hy the use of promissory notes, drafts, and hills of ex change. This distinction, however, has been continuously observed in the act regulating the banking business and is still recognized. It was probably because of the political favoritism shown in granting bank charters and of the bitterness that developed whenever an attempt was made to procure such a charter that the free banking system was adopted hy many of the States. Under this system hanks were chartered under general hanking laws adopted hy the States. As a development of this practice banks were chartered in many States which had adopted no hanking laws, under the general laws applica ble to corporations. The charters granted under general laws lacked uniformity, were very broad in their scope, and in most instances were free from restrictions. It is only in comparatively recent years that the majority of the States have adopted laws regulating .‘i r \ R T W 62U -li the business engaged in by the banks, and it was not until I863 that the Federal Government attempted to create a banking system by the passage of what is known as the National Bank Act. 'When we consider the restrictions placed on the operations of the earlier banks and compare these with the regulations now in force it is apparent that the tendency during the last fifty years has been to liberalize the banking business, and that only those restrictions which have been considered necessary to safeguard the interests of the depositor and customer of the bank have been retained. This is illustrated by the fact that in the fifty odd amendments to the National Bank Act nearly all have been along lines which increase the lending power of national banks. For example, these banks were originally prohibited from lending an amount greater than ten percent of their capital stock to any one person, firm or corporation. By.-an amendment to the Act national banks are now. authorized to lend to any one person, firm, or corporation an amount equal to ten per cent of their cap ital and surplus, provided this does not exceed 30 $ of their cap ital. They were originally authorized to issue national bank notes to the extent of 90$ of the bonds deposited as collateral security. This amount has -been increased to one hundred per cent of the bonds so deposited. They were originally;required to maintain reserve against circulation as well as against deposits. All reserve against circu lation except the 5$ redemption fund was abolished by amendment, and -?s rsz Q J■- «. o Gzk - 12 while the Aldrich-Vreeland Act was in force national hanks were not required to maintain any reserve against Government deposits. Liberality was also shown in the administration of the national hanking laws. For example, in computing the liabilities against which reserves should he maintained hanks were permitted to deduct balances due from hanks from the balances due to hanks, and to carry reserve only against the net balance due to banks. practice has been confirmed by the Federal Reserve Act. This In spite of efforts to liberalize and bfoaden national banking powers, both by legislation and by the administration of the laws, it was generally conceded that national banks were more restricted in their opera tions than their competitors, the State banks and trust companies. Accordingly, to place them more nearly on an equality with State banks and trust companies, the Federal Reserve Act provided for a further increase in the powers of national banks. By this Act the reserve to be maintained against demand liabilities has been reduced. National banks which were heretofore prohibited from lending on real estate have been authorized to lend a limited amount of their resources on farm lands. While they were limited in the amount of money that they might borrow from other banks they have been given the power to rediscount with Federal reserve banks their commercial paper, and have in addition been authorized to increase their lia bilities by accepting bills of exchange or drafts which are based on the exportation or importation of goods; and with a view of co ordinating their powers with those of trust companies many of which ■f . v j >- - 13 - do a commercial tanking "business they have "been authorized to ex ercise, with the approval of the Federal Reserve Board,, the powers of trustee, executor, administrator, and registrar of stocks and "bonds, when the exercise of these powers dees not contravene the laws of the State in which they are located. It will be observed,, therefore, that the banking powers of both State and national banks hare been consistently enlarged and liberalized. It necessarily follows that as these powers are increased, the necessity for proper supervision and regulation is correspondingly increased, and it is in this view that the recent legislation providing for more careful supervision and regulation becomes significant. The danger that follows the failure to regu late the banking business is clearly illustrated by a considera tion of the circumstances, under which State bank notes were with drawn from circulation. It will be recalled that in their inception both State and national "banks performed the functions ox banks of issue as well as banks of deposit and discount. Before the Civil War State bank notes constituted one of the principal mediums of exchange, and their circulation and the power to issue these notes was looked upon as one of the most important functions of banking. Under existing laws, while State banks still have the legal right to issue bank notes, only national banks and the recently created Federal reserve banks exercise this right, culation. State bank notes are no longer in cir The fact that Congress.imposed a prohibitive tax on State c * arv£if\ 62 k - lU - "bank circulation was due in part at least to the lack of uniformity in State hanking laws, and to the lack of supervision and regulation of the business of State hanks. It may he said to be an elementary principle of economics that any substitute for specie currency must have a stable value if it is to be used successfully as a medium of exchange. If a chedit instrument is to be used to discharge other obligations itsvalue must be unquestioned. Accordingly, if a bank note is to be accepted in the discharge of an individual liability, the individual accepting the bank note must be assured that at his option it can be con verted into specie at its fact) value. Some of the States realize this and imposed the necessary restrictions on the issue of such notes. Banks were required to maintain a proper reserve of cash against them to make provision for their prompt redemption and the amount of issue was limited by the laws of the State. Others imposed few if any safeguards. Lit tle or no provision was made for their redemption and the value of the note as a medium of exchange depended upon the reputation of the issuing bank. The inevitable result was that the notes of some banks were accepted at par through a wide section of the country. The notes of others were accepted at par in the immediate neighborhood of the issuing bank, but were discounted when offered in settlement of liabilities in other parts of the country. The notes of still other State banks had little or no value as a medium of exchange. As the States had failed to standardize their banking laws it be lesi came necessary fcsr the Federal Government to pass an Act designed; among other things, to provide for a more uniform currency, and to accomplish in this way what the States had failed to accomplish by not providing for proper supervision and regulation of the banking business. As originally passed the Act of 1863 authorized State as well as national banks to issue their notes on the security of Govern ment bonds. In 1864, however, this provision was omitted when the original Act was amended and re-enacted , and in 1865 a tax of ten per cent was placed on State bank notes which were placed in circu lation. While Congress would no doubt have created the national banking system in any event, since the Federal Government needed these agencies in the conduct of its fiscal affairs, it ia at least probable that, except for the failure of the States to properly super vise and regulate the banking business, no necessity would have arisen for the tax which was imposed upon State bank circulation; and the fact that this necessity did arise demonstrates the value to the banking interests of supervision and regulation. Since 1865 this form of bank credit has not been used by State banks but bank credit in the form of checks, drafts and bills of exchange is still used for many of the same purposes and consti tutes a medium of exchange in commercial transactions in this country. Mr. Brown, instructor in political economy in Yale Univer sity. in his work on International Trade and Exchange, says that it is estimated that more than nine-tenths of the total business 624 - 16 - of the United States is carried on through the use of hank credit. This being true it is manifest that the same necessity for regula tion of the banking business exists today that existed in 13t>4, and this necessity has been materially increased since the banking bus iness has reached such enormous proportions and the powers of banks have been so consistently liberalized. When we examine, however, the adverse criticism of the Federal Reserve Act, and analyze the indictments made against it, many of them seem to be based upon an objection to those provisions which are designed to scientifically regulate the banking business. For example, the officer of a member bank who objects to the Act because he is required to maintain a proper reserve against demand liabilities, and who objects to losing interest on reserve balances usually carried with other national banks,fails to take into consideration that this regulation is in the final analysis a benefit rather than a burden, since it tends to strengthen the credit of the banks composing the System. He fails to appreciate the fact that the purpose of this provision is to provide for an actual reserve to take place of a reserve in form only; and to make this reserve available at all times. He overlooks the fact that ex perience has demonstrated that under the old system it was difficult in times of panic for a national bank to get the benefit of reserve balances carried with approved reserve agents. In estimating his loss from this source he fails to take into consideration that his lending power has been increased: (l) by a decrease in the amount of JjLVJ^ - 17 reserve to be maintained; (2) by his ability to rediscount his commer cial paper with the Federal reserve bank; (3 ) by the use of his credit in the form of acceptances in certain transactions; and that the po tential earnings that may be derived from this increased lending power will more than offset any loss that results from interest on reserve balances. The opposition of an officer of a non-member bank who is inherently opposed to Federal supervision is likewise based to a very great extent upon the assumption that Federal laws are too exacting and are enforced with too great severity. If this is not the basis of his contention it is somewhat difficult to understand why Federal regulation and supervision is less desirable than that of the States. The suggestion that a compact system will be created by remodeling the laws of the several States has been more or less fre quently made. The difficulties in accomplishing this purpose, are, however, at once manifest. If we assume that all of the States could be induced to adopt one standard of banking laws, thus pro viding for uniform regulation and supervision, this uniformity might be destroyed at any time by amendments to the State banking laws of one or more States. The laws of each State would apply to trans actions engaged in within the borders of the State, whereas, each bank, as an incident of its business has transactions with banks and individuals in other States. Legislation might be uniform but the same laws might be administered with great liberality in one and with <I .’ ij 6l - 18 severity in another State. It is not possible within the limits of this discussion to consider the many difficulties involved in this proposal* hut it must be obvious that from a practical stand point it would be exceedingly difficult to accomplish. Conceding that the business of this country can be conducted to greater advantage under a compact and scientific banking system than is possible where it is handled by several thousand unrelated banks, it is manifest that objections made to the creation of such a system must be based upon local considerations. Those who claim that the same objects may be accomplished by less complicated methods apparently assume that it is only necessary to continue to liberalize banking powers in order to meet new conditions and that an extension of banking powers does not necessitate more effective supervision. When we consider that the Federal Reserve Act deals with the various activities of banking; that it provides for a more effective supervision; that it adds to the power of national banks the ability to lend its credit in the form of acceptances; that it concentrates reserves so as to make them available when needed; that it provides a legitimate method for the rediscount of commercial paper; that it adds to the national banking powers the power to lend on real estate to a limited extent; that it permits national banks to act in certain fiduciary capacities; and that it provides a medium by which the sur plus funds of one community may be utilized to supply a deficit in another; and when we recall that this important constructive legis- A lation was not undertaken until Congress had collected and analyzed more information on the subject of banking and currency than has ever been collected by any commission in the history of the world, it is difficult to understand upon what theory it can be argued that the Aidrich-Vree1and Act which merely added an additional method / by which banks might borrow money to be used in an emergency can be said to afford the same advantages that are afforded by the Federal Reserve Act. It is of particular importance at this time that a scien tific and compact banking system should bo perfected. The use of bank credit is constantly increasing in the conduct of the business of this country. In so far as a bankas business is local the repu tation of those who have charge of its management may be a sufficient guarantee of its credit, but when a bank engages in transactions with those who have no personal knowledge of its management, reli ance must be placed upon its statement of condition rather them upon the personnel of its board of directors, and the reliability of this statement must depend to a very great extent upon the character of the laws under which it operates and the manner in which these laws are administered. It is not sufficient that this statement shows an excess of assets over liabilities due to creditors, but the investment of its funds must have been made under laws which provide for proper regulation and supervision of its business. Liberality in banking laws brought about by the single desire to increase earnings may reach the danger mark. The laws 'I -Oi/fiLA 1 ' O U 1* -6 2 4 - -20regulating the banking business are, therefore, an asset of the bank. Every banker has an interest, not only in his own credit, but in the credit of every other bank with which he deals. Few commercial transactions can be completed. that do not involve at some stage the use of credit, and bank credit is generally substi tuted for that of individuals in completing these transactions. It is, therefore, of interest to the banker to see that the laws provide proper safeguards and to cooperate in the enforcement of these laws. Whore the public undertakes by legislation to restrict the exercise of business judgment and to substitute a rule of action prescribed by the law makers, it is necessary that careful considera tion should be given to the interest of the banker. On the other hand, in reaching a conclusion as to the value of legislation, it is equally important that the banker should give consideration to tho public interest as well as to the interest of tho individual bank he represents. A law that places no restrictions on banking opera tions makes it possible for a few to endanger the business of the most conservative, since if public confidence is shaken the whole banking structure is affected. The creation of a compact banking system is particularly important at this time. As a result of the European war this country is called upon to assist many of the neutral nations in financing their commercial transactions. This necessarily involves the use in other countries of tho credit of banks in the United States, and other nations have an increasing interest in our banking laws. J4t OOf?*"* O *• t-624- -21- The National Bank Act has served to accomplish the purpose its advocates claimed for it. Bank note circulation has been placed upon a substantital foundation, and as agencies of the Federal Govern ment national banks have aided materially in the conduct of its fis cal affairs. Many of the disadvantages of the old independent treas ury system have been overcome. With the benefit of more than fifty years experience Congress has been able to determine the defects as well as the advantages of this legislation and the new Federal Reserve System is a development of the system established in 1863. Unlike most of the previous legislation on banking and currency the Federal Reserve Act was not the outgrowth of a demand for legis lation to meet a pressing emergency. Its provisions were adopted after mature deliberation and after an exhaustive study of the future as well as the present needs of the country. Those who are familiar with the intricacies of banking from a practical as well as theo retical standpoint have declared it to be based upon scientific and sound principles. The machinery for a strong and compact system has been provided. This machinery may require some slight adjustments from time to time which will be brought about by amendments proved to bo nocessary by experience. It is free from the objections which occasioned the alarm that was felt when the first and second Banks .then of the United States were organized. The public feared that/their liberties would be endangered by a concentration of power in one mammoth corporation. The present system provides for a co-ordination of the powers of the several thousand banks which compose it, but each bank is an independent corporation owned by independent stockholders and managed by directors selected by the stockholders. It furnishes a legitimate method of cooperation which gives additional strength to each member bank. It provides for a. standard of, regulation and super vision of the banking business which is more permanent than would be possible if the standard established were subject to modification by amendments passed by the forty-eight different States acting in dependently. The rapidity with which this system develops must, of course depend in the final analysis upon the cooperation of the banker. To the layman the advantages derived from membership far outweigh any possible objections which may be based upon the theory that member ship of State banks in this System involves some curtailment of banking powers. The restrictions imposed are only such as experience has demonstrated to be necessary to properly safeguard the interests of those who deal with banks, and the fact that member banks are sub ject to these restrictions and to proper regulation will in the end prove an assetiin the development of its business and not gin obstacle to that development. In times of unusual prosperity when the deposits and resour ces of banks are constantly increasing and there is a surplus rather than a deficit of loanable funds, it is natural perhaps that the banker should feel confident that, acting independently, he should be able to meet any emergency, and that he can obtain such assistance 624 - 23 as may be necessary from other hanks with which he deals. It is in such times, however, that our system should he strengthened and that preparation should he made for any reaction that may occur. If this preparation is made in prosperous times it can he accomplished on more scientific lines than is possible if made only when there is an existing emergency to he met. The economists are not agreed as to just what conditions must he faced following the close of the great European war, hut they are agreed that we can not expect an indefinite continuance of the present prosperous conditions, and that socner or later we must he prepared to meet conditions which are without precedent. It is obvious, therefore, that, in analyzing this legisla tion, the hanker should view the subject from a broad and comprehensive standpoint and should not let purely local considerations influence his judgment. It is equally obvious that any unusual demands that may he made on the resources of this country following the close of the European war can he met with less disturbance to our commercial pros perity by a compact, well organized system than by several thousand unrelated banks each acting independently. It is, therefore, to the interest of the hankers to co-operate in developing a system which will not only insure a continuance of prosperity in this country, hut that will make it possible for the enormous hanking resources of the United States to be utilized to advantage in the readjustment of the world's trade. A system that will enable the hanks of the United States acting as nearly as possible as a unit to .lend all possible assistance in the rehabilitation of the prosperity of those unfortunate countries which are now engaged in this great conflict. 4/21/16, 1009 1070 626 . Washington, D. C> April 22, 1916 OUTLINE OF THE PLAN OF CLEARING AND CHECK COLLECTION ADOPTED BY THE FEDERAL RESERVE BOARD . The Plan proceeds upon the following assumptions and principles: First: A Federal Reserve Bank can not compel an unwilling member bank to send the checks of its patrons to it for collection or clearing, Second: It would be inexpedient at the present time even if legal, upon which no opinion is expressed to compel an un willing member bank to pay at the counter of the Federal Reserve Bank, a check drawn against it (i.e., the member bank) before it has even seen it. The member bank may, of course, authorize the Federal Reserve Bank to redeem at par checks drawn against it and forward them to it for final settlement; or, it may authorize the Federal Re serve Bank to charge t^e checks against its account; Third: In view of the conditions hereinabove stated, and because your Committee believes that the best results will be aecured by a complete co-operation of the member banks with the Reserve Bank, it is proposed that the plan to be followed shall be sufficiently attractive to member banks to appear to them as desirable. Hence, in carrying out this it is proposed to follow the lines of develop- ■ ment which long experience by member banks in their relations with city correspondents has established. This, in effect, means that Federal Reserve Banks shall receive from their member banks, checks, whether drawn against members or non members, or private bankers, and give immediate credit for them; Fourth: Your Committee regards it important that the Federal Reserve Banks shall strictly guard their reserves and that member banks which do not maintain the reserves required by law shall be penalized for deficiencies. In this con nection, the Federal Reserve Bank will not class as reserve - s - 626 any chock?, which-it has received from its members and credited to them but which have not been collected. Fifth: While it is proposed that every Federal Reserve Bank shik.ll render this service of collection for all those mem ber banks who choose to avail themselves of it, it is not contemplated that the service shall be rendered gratis, or without expense to the depositing bank, which is the beneficiary. Therefore, as explained in Mr. Harding’s memorandum, every Federal Reserve Bank shall keep adequate analyses of its clearing and collection expense and charge the depositing bank for the service rendered, the actual cost of that service, as nearly as it may be determined, including interest at a rate to be determined upon and approved by the Federal Reserve Beard, upon all cash advances. On the face of it, this means that a member bank might deposit checks on far distant banks and secure immediate credit at par for these items, and at the same time draw against them before the Federal Reserve Bank has been able to collect.the funds, but, as a practical matter, a member bank could not afford to do this for the reason that it is proposed to charge the member bank, as a part of the expense of handling its checks, the cost of advancing funds; the rate to be charged to be slightly higher than the lowest discount rate established; Sixth: Every Federal Reserve Bank is authorized to receive checks from other Federal Reserve Banks, or under such rules as may be prescribed, from member banks in other Districts, where such routing will save time, but in all cases only for the credit of the Reserve District repre sented by the sending bank and upon terms similar to those upon which it receives checks from its own member banks. Seventh: It is proposed, under this plan, that every Federal Reserve Bank shall be authorized to pay its own member banks a fee for acting as its agent in the collection of checks drawn against non-member banks. Eighth: It is quite likely that it will be found necessary to create collection agencies at various points, especially in Districts of large area. The working out of this system of collection agencies and their establishment is a matter of detail which will follow in due course and will undoubtedly greatly reduce the so-called "float". 1072 MEMORANDUM ON PROPOSED AMENDMENTS TO SECTION 16 OF THE FEDERAL RESERVE ACT NCW UNDER CONSIDERTION BY THE FEDERAL RESERVE BOARD. C. S. H. May 1, 1916, The amendments proposed are designed to seduro live princi pal objects which will b3 considered Separately. I. Bills of exchange and bankers1 acceptances purchased in the open * market by Federal reserve hanks, undor Section 14 of the frodoral JRosorve Act, mav servo as collateral for the issue, by tho Foderal Re serve Agent, ol Federal reserve notes, provided that the accentor or one of the Indorsers is a member bank of any Federal Reserve District.. Under the present law the collateral for Federal reserve notes is limited to notes and acceptances discounted, under.Section 13 of the Act, by the Federal reserve bank for a membor bank and indorsed by the member bank. Under Section 14, however, Federal reserve banks are author ised to buy such bills or acceptances in the open market without the in dorsement of a member bank, but such purchases are limited to paper of the kind and maturity which would be oligible for discount by tho Fed eral reserve bank under Section 13 if offered by a member bank. Such purchased bills and acceptances, when not indorsed by a membor bank, can not be accepted by the Federal Reserve Agent as collateral for the issue of Federal reserve notes, for the reason that they would not represent a rediscount operation with a member bank, and such notes can only be issued, under the present law, when growing out of such a rediscount operation, as it is only through such operations that a member bank Gan avail itself of the reserve deposits required to be maintained in the Federal reserve bank* If such paper were pre sented to the Agent by a Federal reserve bank, the lack of an indorse ment by a member bank would show conclusively that the paper did not grow out of a rediscount operation with a membor bank. • On the other hand, the Federal reserve bank might present paper to the Agent upon which tho last indorsement was that of a mem ber bank, but the paper may have been bought in the open market, 1073 through the medium, for example, of a note 'broker. Under such circumstances, the Federal Reserve Board has ruled that such paper could be received by the Agent as collateral, inasmuch as the indorsement of the member bank makes the paper, in effect, arise out of a rediscount operation whether directly at the request of the member bank or indirectly, a3, for example, through the medium of a note broker. As a matter of fact, the Agent could not know whether the indorsement of the member bank represented a re discount or a purchase, and in such a case the distinction would not be material as the benefit of the transaction enures to a member bank whether through rediscount or purchased After careful consideration the undersigned has reached the conclusion that the law should be broadened so that the Agent may accept as collateral for Federal reserve notes, any bills or acceptances* lawfully purchased under Section 14, which are either accepted by or indorsed by a member bank of ^any Federal Reserve District, To illustrate: A in Buenos Aires s©lls merchandise to B in Boston and, by arrangement, draws a bill of exchange upon a non-member trust company, C in Boston,,payable to the order of A. A then in dorses the bill and discounts it with Bank D in Buenos Aires. D in dorses it and sends it to its correspondent E, a National Bank in Boston. E presents it for acceptances to C in Boston and having in dorsed it, later sells it to the Federal Deserve Bank of New York. It is a matter of some doubt; under the present law whether this bill could be received by the New York Federal Reserve Agent as collateral for the issue of Federal reserve notes, for the reason that, although indorsed by a member bank, it could not have originated out of a rediscount operation with a New York member bank as E, Although a member bank, is not a member bank of the Federal Reserve District of New York, and only member banks of the New York District can V. obtain rediscounts from the New York Federal Reserve Bank, Under the proposed amendment, however, this bill could serve as collateral for Federal reserve notes and there is no reason why it should not be pccbitted so to serve, as the acceptance is guaranteed by the indorsement of a member bank although not of the Federal Reserve District of New York. To take another illustration: A in Buenos Aires, draws a bill, by arrangement, upon B, a National Bank in New York City, payable to A ’s order. A indorses the bill and discounts it with Bank C in Buenos Aires. Bank C indorses it and sends it to its correspondent D a non-member trust company of New York City. D presents it for accept ance to B and then sells it, with or without its indorsement, to the Federal Reserve Bank of New York. Under the present law, this bill oould not serve as collateral for the issue of Federal reserve notes, as, there being no indorsement of a member bank upon it, the bill would show on its face that it did not arise out of a rediscount operation with a member bank. Under the proposed amendment, however, this bill could serve as collateral as it is accepted by a member bank. The real reason advanced for the objection to such a bill serving a3 collateral for Federal reserve notes is not from any doubt as to the due payment of the acceptance, but from the fact that permitting such bills to serve as collateral would have the effect of giving the rediscount privilege to other than member banks, which would be contrary to the spirit of the Federal Reserve Act. It should be remembered however, that the Federal Reserve Act permits Federal reserve banks to purchase such b ills and acceptances in the open market in Order that they may invest tholr available funds at times when there is a falling off in the demand for rediscount opera s'i or that they may make their discount rates effective, tions by member banks£_/ If, therefore, such bills and acceptances can lawfully be purchased under Section 14 there would seem to be no good reason why such purchases; all representing paper which would bo eligi ble if offered for rediscount by a member bank;should not serve as collateral for Federal reserve notes. The fact that thereby benefits are incidentally given to a non-member bank is not a valid objection,because the transaction is entered into for the direct benefit of the Federal reserve bank, and - 4 - for no other^ purpose, member bank The incidental bendfit received by a non not being a valid objection to granting to Federal reserve banks the power to purchase the paper in the open market, should not, by parity of reasonings,bo allowed to serve as an ob jection to Federal reserve banks paying for such purchases by Fed* eral Reserve notes taken out against the purchased paper as col lateral, for the sole benefit of the Federal reserve bank. Under the present law, when such bills or acceptances are purchased from any holder other than a member bank,the payment must necessarily be made in cash, drawing down the cash resources of the Federal reserve bank. The reason for this is that the seller not being a member bank, could not accept a book credit in payment for the sale, and, the acceptance not being eligible as collateral for Federal reserve notes, the bank could not obtain the Federal reserve notes out of thi3 transaction with which to pay for the purchase, Furthermore, under present conditions in the money market, even though the purchase were made f.cr . a member bank on its indorse ment, the member bank would usually take the purchase money in cash, or if accepting a book credit, would at once draw against it. In the latter case, however, if the law were amended, Federal reserve notes could be issued against the pledge of the acceptance which the member bank selling the acceptance very likely would be perfectly w illing to receive in payment. There would seem therefore, to be no good reason for not amending the Act so that paper purchased, having on it the name of a member bank as acceptor or indorser, can serve as collateral for the issue of Federal reserve notes.I. II. Collateral pledged with the Federal Reserve Agent, either gold or pacer, may be withdrawn bv the Federal reserve bank and other col lateral. either -pacer or gold, substituted therefor 6Z1- 1076 - 5 - The present law permits the withdrawal of collateral and the substitution of other like collateral, and this amendment simply strikes out the word “like” , thus permitting the exchange by the Federal reserve bank with the Federal Reserve Agent, of gold for commercial paper, or of commercial paper for gold. Under the present law only commercial paper and bills in foreign trade can be pledged as collateral for Federal Reserve notes. One of the proposed amendments, however, which will be considered in detail later, permits gold to be thus pledged as collateral as well as commercial paper, and if this latter amendment should be enacted into law it will be most desirable to permit the exchange of one kind of collateral for another, as above indicated. III. Federal reserve notes may be originally issued against the deposit of gold with the Federal Reserve Agent to the face value of the notes to be issued, and in such case the Federal reserve bank need not carry in its vaults a 40% gold reserve against outstanding Federal reserve notes so covered by gold. Before considering this amendment it may be well to point out that "issue" in the amendment means issue by the Government, and, further, that notes can only be issued by the Government against the pledge of commercial paper, under the present law, and against commercial paper or gold, or both, under the amendment. The first object aimed at in the above amendment can now be accomplished in effect under the present law, although indirectly, but none the less legally. Before discussing this proposed amendment, there fore, it may be well to consider present methods by which the first re sult reached b y the above amendment is attainable and in fact, attained under the present law. Under the Act, as it now stands, as above stated, Federal reserve notes can be issued by the Federal fieserve Agent only against the de- 631 *6posit of commercial paper. When once the notes have been issued# however# by the Federal Reserve Agent, the present law permits the Federal reserve bank to pay to the Federal Reserve Agent the face value of the notes in gold#receiving back from the Agent the commercial paper originally de posited. This follows from the language of Section l6#which reads as fol lows ! ttAny Federal reserve bank m y at any time reduce its liability for outstanding Federal reserve notes by depositing with the Federal Reserve Agent# its Federal reserve notes# gold# gold certificates or lawful money of the United States. " Wien, therefore# such a payment of gold has been made by the Federal reserve bank to the Federal Reserve Agent the outstanding notes# to the amount of such gold# are in the 3ame position# practically# as if they had been originally issued against gold by the Agent#- with certain qualifications which m i l be explained later. For example# the weekly statement issued by the Federal Reserve Board showing the condition Of the Federal reserve banks on March 17# 19i'S# showed# under the head of ’•Liabilities''# that the twelve Federal reserve banks had# on that day# outstanding Federal reserve notes on which they were liable to the amount of 11.9 millions of dollars# which wae further reduced by 1»7 millions# the amount of such notes held among the assets of the banks# making the net liability only 10.2 millions of dollars. On the other hand# the daily Treasury Statement# published by the Secretary of the Treasury for the same day# showed that there were 1 9 1 . 1 millions of Federal reserve notes outstanding as a liability of the United States Government. Both of these apparently inconsistent statements were correct# for the reason that on that day# while the Federal reservebanJfip bad ■riginally taken out 191*1 millions of Federal reserve notes against the - 7- 631 deposit of commercial paper, they had later deposited with the Federal Reserve Agent, in gold, the sum of 179*2 millions, and thereby, under the clause of Section 16 above quoted, had "reduced"their liability upon 179*2 millions of Federal reserve notes* Thus ;the outstanding Federal reserve notes were in the same position as if 179*2 millions had been originally issued against gbld deposited with the Agent and 11*9 millions or 10 .2 millions net, above referred to, had been orig- ingally issued against the deposit of commercial paper. The statement, made in the last paragraph, that the banks, by the payment to the Federal Reserve Agent of 179*2 millions of gold had thereby "reduced" their liability upon 179*2 millions of Federal reserve notes requires some explanation. What the word "reduced" really means is that the banks, by this payment, are released from the necessity of carrying any re serve against notes so paid and also that they need not henceforth include them among their liabilities. All outstanding Federal reserve notes, however, can be presented at any one of the twelve Federal reserve banks for redemp tion and, therefore, could be so presented to the banks which had paid their full value to the Federal Reserve Agent, as in the example cited above* The banks, therefore, by making the payment of said 179*2 millions to the Federal Reserve Agents, merely reduced their liability to carry a reserve against these notes and are, therefore, permitted, and in fact, required by the clause of Section l 6 above quoted, hence forth to exclude them as outstanding liabilities. The general obligation, however, imposed by the Act upon all Federal Reserve banks,- to redeem all Federal reserve notes, by whatever Federal Reserve Banks issued,- remains undiminished, but is, of course, not set down as a liability in Federal Reserve Bank statements. ~ ' ■ & 31 1079 From time to time criticisms have been made upon the action of Federal reserve banks in taking out Federal reserve notes against the deposit of commercial paper and almost immediately paying their face value in gold to the Agent* taking back the commercial paper* - it being claimed that this* if not a direct violation of the Act* is at least an evasion of the spirit of the requirement that notes can only be issued against commercial paper. Before considering whether this course* thus criticized^ vio lates the spirit of the law* it may be well to point out that there is no inflation of the circulating medium brought about by it* for every note thus issued against the deposit of gold* - whether directly issued* a3 under the proposed awendment*or indirectly* by the course above de scribed under the present law is covered* dollar for dollar* by gold withdrawn from circulation and impounded with the Federal Reserve Agent. Or. the other hand* when the note is redeemed the contraction is overcome % by the return to circulation of the gold impounded. It should also be pointed out*- as will be shown fully later*that if the existing National bank note circulation*- against which no reserve other than the 5$ redemption fund is required*- were to be sud denly wiped out and Federal reserve notes* secured by commercial paper* substituted in its place* an immediate contraction of the outstanding circulation would result from the necessity of carrying a UOf> gold re serve in place of the 5$ reserve carried against National bank notes. What then is the reason for the above outlined process by which the 191.1 millions of outstanding Federal reserve notes have dwindled as a liability of the Federal.reserve banks to the comparatively small amount of 11.9 millions* or* as pointed out above*10.2 millions net* by virtue of the impounding with the Federal Reserve Agent of 179*2 millions of gold t At the outset'* it must be apparent that this impounding of gold with the Federal Reserve Agent must have been of some benefit to the Federal reserve banks, or it would not have been so impounded. What this benefit is * is not difficult to understand. Under the present law the benefit is* 631* j 1080 *» 3 »• (a) If a bank has made an excess deposit of gold and later des to withdraw it, but is willing to accept Federal reserve notes, every available Federal reserve note in the bank vaults will help the bank to satisfy the demand of the member bank without depleting ’ its gold supply, and by securing such notes, by the deposit of gold with the Agent, a gold fund is built up which is available, at any * time, for rediscounting purposes. (b} If the Federal reserve bank finds-that the demands for re discounts by member banks have fallen off so that the bank needs some other source of earnings for its expense and dividend purposes, by paying out Federal reserve notes already issued to it, it can purchase in the open market eligible bills of exchange or bankers* acceptances, (not bearing the indorsement of a member bank, and hence not directly eligible as collateral for Federal reserve notes), and thus secure needed earnings, and, although not retaining the gold in its asm vaults, by placing it in the hands of the Agent, it is rendered available if later needed. It may,however, be pointed out that, leaving out of considera tion excess deposits, a member bank can never draw gold from a Federal reserve bank except by offering commercial paper for rediscount and that such paper when offered for rediscount will serve as collateral for ^ the issue of Federal reserve notes which can be given to the bank if it will take them, in return for the paper rediscounted. This is undoubtedly true, and if there were no excess deposits of gold made by member banks, the only benefit to the Reserve banks, from the indirect method of issuing notes against commercial paper and f later paying gold to the Agent, taking back the paper, would be that described under (b) above, - thus enabling the reserve banks to increase their investments by purchase, with these Federal reserve notes, of bills and bankers' acceptances which could not be directly discounted because of the lack of an indorsement Of a member bank. The underlying spirit of the Federal Reserve Act, however, is to encourage the member banks to make excess deposits. With a satis factory system of check cleanaioes in operation, excess deposits must 631. - 8 a inevitably result. Furthermore, the burden of maintain ing the gold standard of value, although primarily upon the Government, yet will in effect be and is placed upon the Fed- 1081 - 9 - 631. eral reserve banks under the Federal Reserve Act, as they must pay all their disbursements, whether by way of rediscount operations, clearing balances, or withdrawals of excess deposits, in gold. If they ceased to do this, while they could, under the Act, unddubtedly discharge all their obligations in lawful meney, i. e. in greenbacks, silver certifi cates or silver dollars, yet such a course would inspire distfuat and would throw upon the Government a very heavy burden in keeping all our money on a parity with the gold standard, that is, in exchanging for gold the disbursement of the Federal reserve banks made in lawful money. It must also never be forgotten that the business exchanges of the country rest upon a lawful money basis and that it is the duty of the Government to maintain theso exchanges upon the gold standard basis. The Federal reserve banks, through the gold clearing fund, - as between one another, - and by virtue of gold payments to the member banks^are helping the Government materially in keeping all exchanges upon the gold standard of value, and every assistance which Congress can give to tite reserve banks in this work should, and it is confidently believed will, be given. Returning now to the indirect method followed by the banks of taking out Federal reserve notes against commercial paper and immediately paying, in gold, to the Agent, the full amount of such notes, the question arises what immediate gain do the reserve banks derive from this circuitous process. The answer is that when the reserve banks have gold which can not be used for taking out Federal reserve notes, because of tho lack of commercial paper to pledge as collateral for the notes, they have found by experience that they can take notes out against this gold by/circuitous process above referred to and hereafter more particularly described. It is scarcely necessary to add that if the banks have on hand .\ or can ‘Secure an ample supply of commercial paper, their note issuing capacit greater than will be by pledging such commercial paper it could possibly be by paying gold to the Federal Reserve Agent under said circuitous process. Even under such circumstances, however, the privilege afforded - 10 - 631- by the amendment of taking out notes against gold, will enable the reserve banks to conserve their gold^as will be shown more particularly later. To illustrate this circuitous process* above referred to, let us suppose that a Federal reserve bank desires to invest $200,000 in open market purchases of bills of exchange or non-member bank ac ceptances. It holds in its vaults $100,000 in Federal reserve notes taken out against the pledge of $100,000 in commercial paper, and caft obtain no more commercial paper to pledge with the Federal Reserve * Agent for additional Federal reserve notes* Ih does not want to use $100,000 in gold, wfoich it has available for such purchases, but wishes to find some toay by which it can take out $100,000 additional notes against this gold, using these notes for the purchases and thus con serving its gold. By employing the circuitous process now to be described it can take out $1.00,000 in Federal reserve notes* based Upon this golfl paid to the Agent* without securing any more commercial paper to pledge with the Agent for such notes. For example, it already holds $100,000 notes secured by the pledge of $100,000 commercial paper. As a first step it would pay to the Agent $100,000 in gold thus releasing its $100,000 of commercial paper. As a second step, it could redeposit the $100,000 commercial paper with the Agent and take out $100,000 additional of Federal reserve notes. The bank would then hold $200,000 of Federal reserve notes secured by $100,000 commercial paper and $100,000 in gold, and it c.-ould use these $200,000 of Federal reserve notes in making its open market purchases and thus conserve its gold. The above indicates the exact steps taken by the Federal reserve bank which it is claimed, constitute a violation or at least an evasion of the spirit of the law. It is certainly clear that each step taken by the bank, in the above illustration, is in literal compliance with the law. The notes were originally issued on the pledge of commercial paper, and 1083 631. - 11 - and when issued became a liability of the bank. When, however, the bank paid to the Agent $100,000 in gold, the liability of the bank on these notes was from that moment "reduced" The resources of the bank were decreased by the exact amount of the payment in gold, and at the same time the liability of the bank upon the notes was extinguished In other words, at least, in a technical sense, the bank made the payment for the purpose, - to quote the words of the statute, of "reducing". its liability upon the notes. The liability upon these notes, however, thus "reduced" as to the bank, remains undiminished as to the Government, but the Government, to meet its continuing liability, now holds 100$ in gold, through the Federal Reserve Agent, and the Federal reserve notes, a3 to the Government, at least, now become in effect a gold certificate upon which the Government only is liable, but to redeem which it holds 100$ in gold. If there were no demand for Federal reserve notes for circu lation purposes these notes would come back very quickly for redemption* The Government would redeem them and that would end the matter. There being % demand^ howeVer> as we assume^ for suoh notes for circulation purposes, they may remain outstanding indefinitely. The bank, however, from the moment of its payment to the Federal Reserve Agent, has parted * with its gold and has ^reduced1' its liability upon these notes. The criticism, however, might be made that the Government, which originally issued the notes through the Federal Reserve Agent, is now practically in the same position as if it had originally issued these notes against the deposit of gold, rather than of commercial paper, and that the provision of the Act that notes can be issued originally only against the deposit of commercial paper has been evaded by the course thus pursued by the Federal reserve bank. In this connection, however, it. should be pointed out that thi3 same result may be reached directly, even without the payment of gold by the bank to the Agent, in a regular normal way. For example, suppose that a Federal reserve bank takes out $100,000 in Fsderal reserve notes against the pledge of commercial paper, as in the above 1084 631. - 12 - illustration. The Federal rosorve notor. havo no definite maturity, - they remain an obligation until finally redeemed* Let us suppose, however, that the commercial paper runs only for three months. At the end of that period the maker of the paper must pay the notes to the lawful holder, that is, to the Federal Reserve Agent. Th«? Agent will then be in the same position, practically, a3 if the bank had paid him the $100*000 in gold, as in the above illustration, the ddy after the notes had been issued to the bank, - for the cial paper at maturity will payment of this commer "reduce" the liability of the bank upon these notes in precisely the sane manner, whether the payment is made by the maker of the commercial paper at maturity, or by the bank before maturity, In either case, however, the liability of the Government remains unchanged. Tho above would seem to show conclusively that the course taken by the Federal reserve bank, above described, is at least, in technical compliance with the law. The question remains to be answered* however, whetherj admitting suck a technical compliance> the course followed is not really an evasion of the spirit of the law* VTnat, then, is tho spirit of the law?It might be claimed to be that Federal reserve notes should be originally issued only on the pledge of commercial paper, and that a bank should only pay tho face of the notes to the Federal Reserve Agent when it genuinely desires to ."reduce" its liability upon the notes, or desires to secure the commercial paper pledged with the Agent, so that it may be in its possession at maturity ’when the maker or acceptor must pay it, and that the bank, evades the spirit of the law by talking out the notes against commercial paper, but almost immediately paying the amount in gold to the Agent, thus get ting back its commercial paper and leaving the notes outstanding secured by gold as if they had been originally issued upon such security. The question would therefore arise vdiy, assuming, for the sake of argument, that the above course evade.} the spirit of the law, the law should now be changed so as to validate the above indirect process by permitting the original issue of Federal reserve notes against the de posit of gold as collateral rather than against the deposit of commercial 1085 paper. To answer this question we must find the reason why the banks desire this privilege and that reason has already been given, - viz: when the supply of commercial paper is falling off, and yet there is a demand for cash the member banks must draw down their excess deposits in the reserve banks and if the reserve banks can furnish Federal reserve notes it will thereby conserve their gold; or, on the other hand when the reserve banks desire to make investments, and have Federal reserve notes on hand, they can make the investments and still conserve their gold, So also, conversely, when the member bank* have an ample supply of gold they will be glad to deposit it with the reserve banks taking back Fed/ oral reserve notes which at any time they can present to the reserve bank for gold, and the issue of these notes against gold at times when there may be a scarcity of eligible commercial paper, will put the re serve bank in the position of being able to conserve its gold. In the summer of 1914, for example* there was a profound • business disturbance growing out of the European War, and an extra ordinary demand for currency. Coincident with this demand for cur rency there wds threatened a very great depression in business, which would necessarily decrease the amount of commercial paper eligible as collateral for Federal reserve notes. If some future similar emergency should arise, the member banks, not having the power to issue notes, would have to draw down their excess deposits with the reserve banks and pay out the gold thus withdrawn, which would very probably be hoarded and disappear from circulation, while they could meet every demand lor cash if they could receive from the reserve banks, Federal reserve notes. Experience may thus demonstrate that the present limitation upon the issue of Federal reserve notes to the amount of commercial paper pledged as collateral would greatly hamper the usefulness to the community of the issue of such notes, as the required collateral would lend to decrease in amount while the demand for the notes as substitutes for gold might, at the same time, increase. It would seem, therefore, 1087 - 14 - 631. most reasonable to permit the isstie of these notes either against commer cial paper or against gold. So, also, there might arise a demand for gold by some member bank for export, and in this event, if the Federal reserve bank had the necessary amount of gold deposited with the Federal Reserve Agent,whether under the circuitous method used under the present law, or pledged with the Agent, under the amendment, it could obtain this gold tram the Agent by substituting the consnercial paper rediscounted by the member banks to secure the gold, and thus give to the member bank the gold so withdrawn from the Agent* An interesting table, prepared by Federal Reserve Agent Jay, (Appendix X and II), demonstrates that gold thus withdrawn from the Agent’s possession does hot diminish the credit power of the Federal reserve bank, but, on the contrary, protects that credit power from the inevitable de crease resulting from the payment of the gold directly from the bank’s vaults* Mr, Jay shows conclusively that the gold thus deposited with the % Federal Reserve Agent Increases the credit power of the bank to the extent of 50$ of the amount of gold deposited. The proposed amendment would also, at the present time, at least, operate most conservatively, correcting any present tendency toward undue oipansion caused by the great inflow of gold into the United States, for every dollar of this gold which could be secured by the Federal re serve banks from member banks in return for Federal reserve notes, would be taken out of the vaults of the member banks and impounded in the Fed eral reserve banks. Furthermore, every dollar of gold which a Federal reserve bank could deposit with the Federal Reserve Agent as a basis for Federal reserve notes would be a use of this gold by the issue of the notes simply dollar for dollar; that is to say, there would be no expan sion whatsoever in the circulating medium, because for every, dollar of notes issued by the Federal reserve bank a dollar in gold would be im pounded with the Federal Reserve Agent. 631. The amendment, furthermore, would enable the Federal re serve hainks to lay down and maintain, under the guidance of the' Federail Reserve Board, a uniform, National policy of conservation of the gold supply of the United States, For the above reasons, it would seem most advisable that the law should be amended, 1088 1089 631- - 15 - as indicated above, so that Federal reserve notes nay be issued by the Federal Reserve Agent against the deposit of gold as well as of com mercial paper. The adoption of this amendment would a.lso correct the curious anomaly, - pointed out above, - the4*re^uc^^onr of the bank’s but not of Governments the •/Liability, - which results from the payment to the Federal Reserve Agent by the bank, in gold, after the original issue of the notes against commercial paper; for under said amendment the Federal reserve notes, instead of being paid in gold after their issue by the bank, as under the present circuitous process, will be issued originally to the bank upon the deposit of gold, so that as a result the liability of the bank upon these notes will continue the same as the liability of the Government, - until their final redemption. The apparent inconsistency between the Federal reserve bank statement and the Treasury statement, pointed out above, will also be * removed by the passage of the amendment, and the total note liability, both of the banks and of the Government, will be the same, that is, they both will be liable for the total amount of Federal reserve notes out standing, until final redemption, and the two statements will be in perfect harmony. The above amendment also provides that where a Federal reserve bank has taken out Federal reserve notes on the deposit of gold with the Agent it need not keep the reauired ^40$ gold reserve in its vaults _____ against such notes. In the indirect operation described above, whore the bank takes out the notes originally against the pledge of commercial paper but later pays the full amount in gold to the Agent, the bank, after the payment, need keep no gold reserve in its vaults against these notes, fo1" the good and sufficient reason that the payment of the gold has ‘‘reduced*' its liability *©n these notes; therefore, no reserve need be maintained. *-— Similarly, under the proposed amendment, the original issue of Federal reserve notes to the reserve bank against the deposit of 100$ gold, will leave the bank liable upon these notes as well as the Government) - 16 - 631. but the Government having in its hands 100$ in gold with which to pay them, the bank need keep no reserve, for, if presented by the holder to the bank for payment the bank would merely turn the notes over to the Agent who would redeem them from the 100$ in gold in his possession for this purpose. The exact measure of expansion under this proposed amendment, as compared with the maximum expansion under the present law will be shown in detail later. IV. The right of the Federal reserve bank, described above under HI. to nav to the Agent in gold, etc., the full value of outstanding Federal reserve notes and thus "reduce" the liability of the bank upon s_uch n otes is repealed by the omission of the paragraph of Section 16 hereinbefore quoted, granting this privilege. It is also provided that any rate of interest which mav be charged bv the Federal Reserve Board unon Federal reserve notes sh3.ll not be applicable -to such notes when and as lone as secured bv gold deposited with the Agent. The object sought by this proposed amendment is to maintain the liability of the banks upon all notes issued until they are finally redeemed, thus making the liability precisely the same as that of the Government. This change will also bring about, harmony between the daily statement of the Treasury and the Federal reserve bank statement, and will remove the apparent inconsistencies pointed out above under III, It would seem also desirable to provide, - as does the pro posed amendment, - that in so far as the Agent holds gold pledged against outstanding notes, the bank should be released, pro tanto, from payment the of any interest charge imposed by the Federal Reserve Board upory1out standing notes, as such notes,. - in so far as they are secured by pledge gold, do not constitute, an increase in the circulating medium, but are, to the extent that gold is pledged against them, - to all iaients and purposes, merely gold certificates. Under such circumstances it would seem as unreasonable to impose an interest charge on such proportion of the notes, thus secured, as it would be to impose such a charge upon the gold for which the notes have become, pro tanto, to all intents and purposes, merely a warehouse receipt. 1090 Federal reserve notes ma y also be issued not only against the deu •posit of 100$ in gold with the Agent, but as well, against the deposit of paper and gold, and further, the gold so deposited as collateral with the Federal Reserve Agent shall be counted pro t ant o and included as if in the vaults of the bank as its gold reserve against outstanding Federal re serve notes in actual circulation. To illustrate: 1* Suppose a Federal reserve bank takes out one million dollars in Federal reserve notes pledging, under the amended law, as collateral 60$, or $600,000, in eligible paper and 40$, or $400,000, in gold. The effect of the above amendment would be that the reserve bank would count the $400,000 gold deposited with the Agent as its 40$ required gold reserve just as if it were actually carried in its vaults, and need carry no reserve in its vaults against such notes. 2. Or, in the alternative, let us suppose, that the reserve bank takes out one million dollars in Federal reserve notes, pledging, under the amendment, as collateral, 80$, or $800,000,in commercial paper and 20$, or $200,000, in gold. The $200,000 deposited with the Agent would count as one-half of the required 40$ reserve, but the reserve bank would have to carry $200,000 gold as reserve in its vaults, which, together with the $200,000 deposited with the Agent, make up its required 40$ gold reserve. Under stach circumstances, however, the bank would probably deposit with the Agent the $200,000 free gold, and take back a similar amount of commercial paper, leaving the situation the same as in 1. supra. 3. Or, again, let us suppose that the Federal reserve bank takes out one million dollars of Federal reserve notes, pledging with the Agent, as collateral, $400,000 paper and $600,000 gold. Under the amendment, the Federal reserve bank would be in the same position as if the $600,000 gold were still in its vaults, that is, it would have $400,000 as a 40$ gold reserve and would have $200,000 free gold which could serve as a reserve for further issues of Federal reserve notes, but not as a reserve against deposits. 631« i1092 - 17 a - It is to be noted that illustrations 1 and 2 could be as pointed out supra, indirectly accomplished under the present law, by the payment of gold to the Agent after the notes had been issued \ \ . \ \ \\ \ , - 18 - 1093 631 • against 100$ commercial paper, i.e. the.same situation would result, the notes outstanding would he the same - one million dollars - at least as to the Government liability; - and the Agent would hold com mercial paper in part and gold in part as collateral, - 100$ in all. The reserve situation, however; would be very different, comparing the present law with the proposed amendment. For example, under 1. supra, the $400,000 payment to the Agent would cancel the banks liability cn $400,000 Federal reserve notes but the bank would have to carry in its vaults a gold reserve of 40$ upon the $600,000 Federal reserve notes covered only by com mercial paper, i.e. a gold reserve of $249,000. So also in 2. supra, under the present law, the bank must carry in its vaults in gold 40$ of $800,000 or $320,000. So also, in both 1 and 2, supra, under the present law, the payments to the Agent would be subtracted from the gold resources of the bank. Under the proposed amendment however, in illustration 1 supra, the payment of $400,000 to the Agent would not extinguish the liability of the bank upon $400,000 of Federal reserve notes. On the contrary, these notes would remain as an outstanding liability of the bank. So also, the bank would not have to keep any reserve against these notes in its vaults, for the $400,000 pledged with the Agent counts as if it were in the bank vaults, a3, instead of being raid to the Agent to reduce liability it is now pledged with the Agent as security for a continuing liability, and being counted as if actually in the vaults of the bank it would count as its 40$ gold reserve. So also, in 2 supra, under the amende! law the $200,000 pledged with the Agent would necessitate only $200,000 gold to be carried by the bank in its vaults, instead of $320,000, as under the present law. So also, in 3 supra, the bank would count the $600,000 deposited with the Agent as if it were cash in the vault and it could, therefore, have, theoretically, its 40$ gold reserve and also $200,000 free gold / 1094 631, - 19 actually in its vaults* as a basis for further Federal reserve note issues. The first objection which may be advanced against the pro posed amendment is that it permits an expansion of note issues, ! As 1 iatt, however* rashere the bank can secure ample commercial paper, no more notes could be issued under the amendment than uijder the present law, and the amendment would merely permit a substitution of gold as collateral in the place of commercial paper, \ On the other hand, assuming that the bank has e, g. 400\mil~ \ lions of free gold and only 600 millions of commercial paper, the atoendment would admit of an additional note issue limited to the exact amount of the gold deposited with the Agent as collateral, „ \ The total note issue, however, could in no event exceed 100$ and of the total collateral, paper Igold, pledged with the Agent; nor could the total note issue in any event exceed 2t times the free gold owned by the bank, - 400 millions, - whether the gold is held in the bank's vaults or pledged with the Federal Reserve Agent. v It would seem reasonably clear that expansion to this extent is not undue but is consistent with soufcd banking, It should also be pointed out that, whenever Federal reserve notes are placed in circulation as a substitute for retired national bank circulation an actual contraction of the circulation takes place. This will at once be seen from the following tables. example, there are today about 735.7 millions of national \ \ For 1095 - 20 - 631. bank notes in circulation and about 1928 millions in gold coin or certificates* Let us, then, assume that these National bank notes are removed from circulation over night and that their place is to be filled in the circulation by an equivalent amount of Federal re serve notes, the Federal reserve baixks having an ample supply of commercial paper to pledge with the Federal Reserve Agent against the issue of the Federal reserve notes. Tbe-account would stand: ■ Reserve, 735*7 735*7 I 1928 3 6 ,8 2663 *7 735.7 u. s. bonds — 2. Federal Re serve Notes Notes and Security held gold in cir-by U.S.Treasurer culation or F. R. Agent 1 ;! ~ m 1. National Bank Notes Gold in circulation 1 294.2 Contraction 1670.6 24 o 6*3 257.4 257*4 735*7 Commercial . . . . . . . paper. Thi3 shows that, under Section l6 as now in force, if millions of Federal reserve notes were substituted fDr the 735*7 735*7 mil lions of National bank notes now outstanding, the gold reserve require ment for Federal reserve notes would result in a contraction of gold in circulation of 257*4 millions, - the amount of the excess of said gold reserve, - 294.2 millions, - over the reserve required for National bank notes, - or 36.8 millions. Let us now suppose that the proposed-amendment has been enacted into law, and that the Federal reserve banks have only 44l»5 millions of commercial paper, and that they take out 735*7 millions of Federal reserve notes by pledging 44l«5 millions in commercial paper (60$) and 294.2 millions <40$) in gold. The account will then stand: 631 1096 21 - Reserve 1. National lank notes 735.7 2. Federal re serve notes Present law 735.7 1928 2663.7 735.7 U.S. Bonds 1670.6 2406.3 735.7 Commer cial paper V 3. Federal re serve notes Law as amended 735.7 4. Federal re serve notes 36.8 Security held by Notes and U.S.Treasurer or gold in Gold in F.RJUent dirculation circulation 1164.8 294.2 (36,8 + 257.4) (294.2) (36.8 + 257.4) 465.9 (36.8 +429.1) 1670.6 1498.9 2406.3 2663.7 (441.5 com(mercial 735.7( paper (294.2 ( gold . 1164.8 Commer cial naner Line 3 above shows just what the proposed amendment would accom plish, - it permits the bank to carry its required reserve in the Federal Reserve Agents' trust fund where it is available for the issue by the Agent of 294,2 millions of Federal reserve notes, dollar for dollar. It will be noticed that the reserve of 294.2 millions in line 3 supra, is put in brackets, for the reason that it is not in faot in the bank vaults but is carried by the bank, - as the amendment permits, with the Federal Reserve Agent. The gold in circulation is, however, contracted by the same amount, - 257.4 millions net, - as though the notes were issued as in line 2, under the present law, the same reserve being required, but permitted to be carried, under 3, with the Federal Reserve Agent. It is interesting to note here that', in order to prevent any contraction in the total notes and gold in circulation, - 2663.7 millions, as shown in line 1, a much larger amount of Federal Reserve notes would have to be issued. This can be shown by the following algebraic formula: Let X s the required amount of Federal reserve notes to be issued. Then 40/l0Q X will be the required new reserve. The formula will then stand: X - 735.7 - 2/5 X - 36.8. That is to say the new amount of notes to be talien »ut minus the 735.7 millions now outstanding will equal .the new required gold reserve minus 36.8 millions, - the amount of the 5% redemption fund for national bank notes: Then: X - 735.7 + 36.8 = 2/5 X X - 698.9 I 2/5 X X - 2/5 X ! 698.9 3/5 X I 698.9 X/5 = 232.96 X = 1164.8 Transferring these figures to line 4 in the above table, we will see that to keep the total notes and gold in circulation the same as when the national bank: notes were outstanding, there must be issued 1164*8 millions of Federal reserve notes, instead of 735.7 millions. The gold in circulation would then be contracted by 465.9 minus 36.8 millions (the amount of the 5$ national bank redemption fund) Z 429.1 millions, but the same amount, - 421.9 millions, - of Federal reserve notes would be added to the 735.7 millions of notes outstanding, and this would make the total notes and gold 2663.7. mill ions, - the same amount as was outstanding in line 1 of the table. This issue could not be made, however, unless the banks had or could secure 1164.8 millions of commercial paper. It may be asked, however, what amount of Federal reserve notes the reserve banks could issue under the present law, by using the cir cuitous process above described, that is, by paying to the Agent all free gold in the bank‘s vaults, thus releasing a similar amount of com mercial paper, and then repledging the Commercial paper for a similar amount of additional Federal reserve notes. Using the process above described, assuming that the reserve banks have only 441.5 millions in commercial paper and 294.2 millions in gold, they could take out only 441.5 millions of notes against the pledge of commercial paper, but could then pay their free gold, - 117.6 millions (the balance, - 176.6 millions being held as a 40$ gold reserve against the 441.5 millions of notes outstanding) to the Agent, taking back 117.6 millions of commercial paper and later repledging the com mercial paper for 117.6 millions of additional Federal reserve notes. 1098 631. - 23 Thd account would then stand: Rediscounts 441.5 Federal Reserve Rotes 441.5 Rediscounts 441.5 Gold Capital F. R. Rotes 294.2 117.6 F. R. Rotes 559.1 117.6 735.7 Gold 735.7 559.1 559.1 Thus, hy using the circuitous process, the Federal reserve banlcs, under the present law, could taka out 559.1 millions of Federal reserve notes, being 117.6 millions more than they could take out with out recourse to the process above described; the additional 117.6 millions of notes, however, would constitute a liability only of the Government and not of the banlcs. The following table gives the results of the various methods above described: (See following page) a 05 © Notes 1. National Bank 735.7 Notes Present Law: 2. Federal Reserve Notes Notes issued vs. com. paper 735.7 Direct method Federal Reserve Notes - Present Law: Notes issued vs. com. paper Direct method To make total notes plus Gold in circulation the 1164.8 Same as in 1_________ Federal Reserve Notes Assuming Federal Reserve Banks can secure only 441.5 com. paper and 294.2 in gold. Notes issued vs. com. paper Direct method____________ 441.5 03 ___ Same as 4 Federal Reserve Notes . 5. Clrcuitous method *559.1 Proposed amendment. 5~ Federal Reserve Notes Assuming reserve hanks can secure only 441.5 com. paper and 294.2 in gold. Notes issued vs. com. 735.7 paper and gold_________ Reserve 36.8 Notes and gold Gold in circulation in circulation 1928 Security held >y U. S. Treasurer or . R. Agent. 2663.7 735.7 U. S. bonds (36.8 f 257.4) 294.2 1670.6 2406.3 735.7 Com. 1*Lper (36.8 i 429.1) 465.9 1498.9 2663.7 1164.8 Com, laper (36.8 I 139.8) 176.6______ 1751.4 (36.8 Z 139.8) *176.6_____ *1670.6 2192.9 441,5 Com. Pacer (* 441.5 Com. Paper (*117,6 Gold I (36.8 Z 257.4) (294.2)_____ 1670.6 *2310.5 (441.5 Com. Paper (294.2 Gold 2406.3 735.7 * Note that the reserve in 5, - 176.6, - is the same as the reserve in 4, yet that 559.1 notes are outstanding in 5 and only 441.5 in 4. The reason is that the payment to the agent of 117.6 millions of gold operates to "reduce'’ the liability of the banks on that amount of notes, while the liability of the Government isincreased by 117.6 millions. The banks being liable only on 441.5 millions of notes need keep a reserve only against 441.5 millions. Note also that the contraction of gold is the same in 2 as in 5, for the 117.6 millions of gold is taken out of circulation equally whether held in the bank’s vaults, as in 3, or held by the Agent, as in 5. V 1100 -6j 1- -2'j- The above table clearly*shows that, - when the banks have an ample supply of commercial paper, - the amendment causes no expansion of notes. It merely permits the same amount of notes to be issued, but the requirement of the present law that the Agent shall hold 100$ com mercial paper is contracted to 60 $, and the balance is made up of gold. Tho table also shows that when the banks can not secure as much commercial paper as their gold would sustain as a reserve for Federal reserve notes, i. e., 2g- times as much, there is an expan sion, dollar for dollar, by the exact amount of gold pledged in lieu of commercial paper, but tho total amount of notes outstanding can never exceed 2g- times tho total gold held by the banks, whether in their vaults or pledged with the Agent, nor can the total amount ever exceed the total amount of collateral, whether paper or gold, pledged with the Agent. It may be claimed, however, that in 3 supra, the 29^.2 mil lions of gold serves two purposes, - both as reserve in the bank's vaults and as collateral with the Federal Reserve Agent, - and that this gold cannot serve two masters at the same time. This latter proposition is undoubtedly true, but it has no application to the present case, for although this 29 ^ *2 millions of gold stands for two purposes and thus, in a sense, may be said to serve two masters, it does not stand for both purposes or serve two masters at the same time; on the contrary, it stands in the alternative for either at any time. but not for both at the same time. and there is nothing incon sistent or impossible in this dual but alternative relation. A similar alternative use of the 40$ gold reserve is found in another portion of Section l6 which provides that the Federal Reserve Banks must keep on deposit in the United States Treasury not less than 5$ in gold as a redemption fund, but that such deposit of gold shall be counted and included as part of the Uo$ gold reserve to be main tained by the Reserve Banks in their vaults. Unquestionably, tinder this clause, the Federal Reserve Board, at the request of the 1101 Secretary of the Treasury, could require the Federal Reserve Banks to de posit their whole 40$ gold reserve with the Treasury, and we should then see this gold reserve serving two masters, but the service would be only an alternative service just as in the proposed amendment. VI. Let us now work out, step by step, just what note issuing power a Federal Reserve Bank has under the present law and what it would have under the suggested amendment, assuming only a limited supply of commercial paper. In Appendix II, this has been worked out in detail by Federal Reserve Agent Jay and in Appendix III by Mr. Jacobaon, of the Statistical Division of this Board, based upon the present resources, upon certain specified days, of the twelve combined Federal Reserve Banks. It may, however, be easier to follow the various steps by taking a simpler illustration. We will, therefore, assume that a Federal Reserve Bank has, say, 400 millions of ’•bapital which has been paid in in gold and that the bank has discounted 600 millions of com mercial paper for member banks, pledging said commercial paper with the Federal Reserve Agent for Federal reserve notes which the member banks wish to draw out against their rediscounts. i The bank must keep in its vaults 240 millions of gold reserve against the 600 millions of Federal reserve notes outstanding, and thus has left 160 millions in gold which is free. The bank would like to impound this gold and at the same time use it in the shape of Federal re serve notes so as to derive earnings from it. We will assume that the supply of eligible paper has fallen off and that the Bank can secure no more so that it can not utilize its 160 millions of free gold for taking out Federal reserve notes, having no eligible paper to pledge.( * ) (*) By the term "capital", free gold is meant, in all the following tables. The term "capital" is used in order to distinguish the free gold, entered under this heading, from gold creating deposit liabilities and requiring a separate 35$ reserve. -27- .6 3 1- We will further assume, however, that paper eligible for purchase in the open-market ( hut not eligible for rediscount for lack of the indorsement of a member bank,) or U* S. bonds or Municipal warrants for any part of bOO millions? have been offered to the bank and that it is prepared to buy in the open-market as much of these as it can pay for by the issue of Federal reserve notes based upon the 16 0 millions of free gold in its vaults, assuming, at the same time, that those who offer these securities or paper for sale are willing to accept Federal reserve notes in payment* The question which then arises is what amount of Federal reserve notes can the bank, under the present law, take out and issue against this 160 millions of free gold* We can then com pare this with the amount of notes which can be issued under the pro posed amendment* The answer to this question will be found from an 1102 ,P 631 “’<£»O v~ PRESENT LAW I. The Federal reserve bank starts with 400 millions of capital paid in in gold. It has discounted 600 millions of commercial paper for member banks, pledging said paper with the Federal Reserve Agent against the issue of Federal reserve notes which the member banks draw out against their rediscounts. It desires also to invest in open market purchases, United States bonds, or warrants as above assumed. The account of the Federal reserve bank will stand as follows; Reserve Bank, Rediscounts “'600 pledged W ft Redisceunts ______ free Redi3C ounts total 600 Gold paid to F.R.Agent ! Gold in bank 400 vaults Geld total 1 400 F. R. Notes ^Ui-_T ,im m m ** 4 Federal Reserve Agent. F.R.Notes 'Too Rediscounts j 1 600*'* ¥ 1 Capital 400 J,,,,. ,— m m m Jtoi.____11*000.__ ■'“ .. . ... 1Gold mamrrw.. m. . m »— ........... J --- ---- .-------*» i \ j -4 j^poo,........ n ..... 1600 F. R. Notes ^ .«• . ... 600 r 6po5 Reserve. 40% of 600 - 240 Free gold * 400 - 240 * 160 Credit power. F. R. notes * 'l\ x 160 * 400. The bank here has 160 millions free gold but it can not take out Federal reserve notes against it directly under the present law not having rediscounts to pledge, all its rediscounts - 600 millions having been already pledged with the Federal Reserve Agent. The bank, however, can indirectly, but none the less legally, make a further is sue of Federal reserve notes, even on its present holdings of redis- 1103 631 -20counts, by taking two steps as follows: 2. £ t_ e £ 1. The bank pava 160 millions of gold which it has in its vaults free, to the Federal Reserve Agent, taking back 160 millions of rediscounts from the Federal Reserve Agent, under the provisions of Sec. 16 above quoted. The account will then stand: Reserve Bank Redisc bunts L pledged 440 F.R, Notes 440 ■ n » i » i . wRediscount s.III naifuuo m «iii Km Red iscounts free_____ 160 Capital 400 Gold 160 Red isc ounts total 600 Gold paid to F.R. Agent (160) Gold ..... . in v a u l t ____240 Gold total 240 F. R. Notes - " B 40840 F.R.Notes_ 600 ------ Reserve. 40?. of 440 « 176 Free gold s 240 - 176 s 64 Credit power, F. R. Notes 8 2f x 64 B 160 This operation leaves the bank with 160 millions in free rediscounts upon which a further issue, of Federal reserve notes can 2. S t e £ be taken out. 2» Let us assume that the Bank repledges the 160 millions of free rediscounts and that it takes out 160 millions of additional Federal reserve notes. The account would then stand: Re servo Bank Federal Reserve Aerent. Rediscounts ‘’"Re-' “ pledged 600 F.R.Notes __600 Rediscounts Gold __ 160 . ___ free.____ »>waCapital n— -•**•mmmi -w 400 — -- ’--- --— Rediscounts {' 600 t o t a l ___ Gold paid to F . R. Agent .(ML) --- ■- **-----— — ., — ...-~ Gold in vaults 240 GQld •■• total ~240“ F.R.Notes .„ .,. ,* . -. . J.’TL'iipA®.®..-. .7 .60. . ___ ML ' Total L.occ ^ l.coc' .... . ..7.60 ,... . ' . .■ 760 ... 1104 1105 Reserve. 40% of 600 ■ 240 Free gold ■ 240 - 240 a 0 Credit power. F. R. Notes a 0 Thus by the two steps above described the Bank has paid 160 millions to the Agent and has thus ^reduced" its liability on 160 millions of Federal reserve notes. This payment, however, has released 160 millions of rediscounts which have been repledged for 160 millions of additional notes. reserve notes 160 The bank'A liability for Federal remains as before at 600 millions being offset by the 160 millions, the additional millions on which the bank's liability was '’reduced” by the payment to the Agent. As the notes are all outstanding, however, the liaoility of the Government is in creased by 160 millions and now stands at 760 millions. The oank still has 240 millions of gold in its vaults, but this 240 millions it must keep as a 40$ gold reserve against the 600 millions of Federal reserve notes outstanding. The total note-issuing power of the bank is thus seen to be 760 millions. It could therefore issue 160 millions of addition al Federal reserve notes for the purpose of making investments other than regular discount operations, for which latter, as assumed above, « there is no demand, and these additional 160 millions would be a liability only of the Government. 3. Let us now assume that the proposed amendment has become law and that henceforth Federal reserve notes may be issued by the Agent originally against the deposit of gold, commercial paper, or both. jLf-Of> -31- -631- Going back to I, we will assume the Bank pledges its 160 millions free gold with the Federal Reserve Agent instead of paving it in order to reduce its liability. The account will then stand ; Reserve Bank Federal Reserve Agent Rediscounts Pledged 600 F, R,Notes 760 Rediscounts 600 __ Free 1601 Capital 400 Gold F.R.Notes Total 600 Gold * Pledged 160 Free 240 ... Total 400 F.R.Notes 16C Total H60 760 1160 760 760 Reserve 40$ of 760 = 304 Free gold, 40C-304 = 96 Credit power, F.R.Notes * 2~g X 96 = 240 By this process, under the amended lav, the pledge of 160 millions gold, instead of."reducing" liability on 160 millions of Federal reserve notes as was the case in II, steps 1 and 2, supra, has increased the lia bility of the bank by the amount of additional Federal Reserve notes taken out, - 160 millions,- and the bank, as also the Government, is liable on the total,- 760 millions. Note also that the bank has in fact only 240 millions gold in its vaults and 160 pledged with the Fed eral Reserve Agent. The amended law, however, provides that the 160 against Federal reserve notes millions pledged with the Agent shall count as reserve/as if actually held in the bank’s vaults-, The total gold in the bank’s vaults- 240 millions should, therefore, have added to it the amount pledged with the Agent- 160 millions, making a total of 400 millions. We saw above under II, step 1, supra, that a payment to the Agent under the present law reduced the cash in the bank’s vault to 240 mil lions while on the other hand the liability of the bank on Federal re serve notes -was reduced to 440 millions. 631. -32- Under the amendment, however, th9 160 millions of gold pledged with the Agent is still counted as bash in the bank’* vault3, while, on the other hand> the 160 millions of additional Federal reserve notes taken Out by the bank instead of reducing its liability to 440 millions, increases its liability on Federal reserve notes from 600 to millions, making it the same as the liability of the Government. 4. We saw also under II, Step 2, supra, that the bank had 240 millions of gold in its vaults which it could not utilize for further issues of Federal reserve notes as it had to serve as a 40$ gold reserve against the 600 millions of Federal reserve notes outstanding upon which the bank was liable. This 240 millions, however, is not a trust fund for, the redemption of the notes but merely a gold (cash) requirement. Inasmuch as the amendment provides that this gold reserve may be deposited with the Federal Reserve Agent and still be counted as if in the bank vaults let us suppose that the bank transfers i.e. pledges this 240 millions of gold with the Federal Reserve Agent. By this transfer or pledge, what was reserve before now becomes part of the Agent’s trust fund, but being gold, it also, under the amendment-, satis fies the gold (cash) reserve requirement as if it still were in the bank’s vaults. After such transfer, the account would stand: Reserve Bank Re discount s: Pledge d Free Gold - Total 600 Pledged Free 4 oo Total Uoo F. R. Notes Capital 1000 400 Rediscounts Gold 600 400 F. R. Notes IOC '- * 4 oo 2 , R. Notes 600 Federal Reserve Agent Total i 4 oo 1400 1000 1000 1108 -33- Reserve: d^a . H(# of 1000 - Uoo Free gold 400 - H00 = 0 Credit power, Federal Reserve Notes = 2|* x 0 = 0 In the above statement the gold in the bank vaults is entered as U00 millions. In fact there is not a dollar in gold in the vaults, as it all has been pledged with the Federal Reserve Agent, but, under the amendment it counts as reserve in the bank vaults. V. Let us now consider just how great an expansion of credit power in the shape of Federal reserve notes has been made possible by the provisions of the amendment that gold deposited with the Agent shall count as reserve in the b-nk's vaults. V,re here still assume that 600 millions represents the maximum of eligible paper the bank can secure. We saw above under I that the bank had l60 millions in free directly gold bpt could not take out Federal reserve notes/against it because it had no free discounts. Under tho amendment, however, the Agent can issue Federal reserve notes against the deposit of this gold. We also saw in II, Stepsl and 2, that by paving this l60 millions in gold to the Agent the bank received back l60 millions in commercial paper and that this paper was redeposited with the Agent and l60 millions additional notes taken out but that although the bank was liable on this additional l60 millions, it had also, by the payment of 160 millions i,reducedn its liability on notes to an equal amount, and that therefore, the bank remained liable only on 600 millions, as before, while the Government liability had increased to 7^0 millions. We also saw under III that under the amendment, the bank could pledge this 160 millions of gold with the Agent and thereby increase the total note issue outstanding fron 600 to jSO aillio$ upon which both the bank and the Government were liable. We also saw that under the amendment the bank could also pledge its 2U0 millions of gold held as reserve against the 600 millions of out 34 standing Federal reserve notes, with the Agent.and take out 2U0 millions of additional Federal reserve notes. To find, therefore, the true measure of expansion under the amdndment we must consider; (a) the effect of the payment of l6o mil lions of gold to the Agent, under the present law, as compared with; (b) the effect of the pledge with the Agent of l60 millions of gold under the amendment, and (c) the effect of the further pledge of 2^0 millions o| gold with the Agent. We find that (a) increased the total note issue l60 millions while (b) increased the total note issued by 160 millions, and (c) by 2 U0 millions, making a total of HOQ millions in all. ■631- -35- That is to say, the payment to the Agent left the hank under the present law, with only 240 millions of gold which constituted its gold reserve of 40$ against 600 millions of Federal reserve notes out standing! while under the amendment, this 240 millions is actually de posited with the Agent> authorizing the issue hy him of 240 millions of additional Federal reserve notes, but the 240 millions , as also the 160 millions above mentioned is counted a3 if still in the vaults of the bank* In the bank's vaults,this 160 1 240 ® 400 millions stands as a reserve for 2f X 400 millions of Federal reserve notes, while with the Agent it stands for the issue, dollar for dollar, of 400 millions Federal reserve -notes, while the 600 millions of com mercial paper pledged with the Agent serves as collateral for 600 millions of Federal reserve notes. The Agent then holds 100$ in collateral,- 600 millions in commercial paper and 400 millions in gold, while the 400 millions of gold,is counted as reserve in the bank's vaults, and serves as a gold reserve for 2^ X 400 millions s 1000 millions in Federal reserve notes,the exact amount issued by the Federal Reserve Agent. This shows that the real effect of the Amendment is to consolidate, for Federal reserve note purposes, the gold held by the bank with that held by the Agent, that is to say, the gold held by the Agent serves as if actually held in the vaults of the bank. Going back to II, Stop 2 , we see that after issuing the maximum amount of notes possible under the present law, the ac count of the bank and Federal Reserve Agent stand as followsiwwj/ 2 w. %____________ Federal Reserve Agent Rediscounts Pledged 60G F. R. Notes 600 Rediscounts 60C " Free Capital 400 , Gold 160 " Total 600 Sold Paid to F.R.Agt,&60) " in vaults of Banks240 " Total 240 F.R.Notes 160' F.R,Notes 760 Total 1000 760 1 760 1000 r Reserve Bank_______ l ! . 1111 — 3 6 — 631, Reserve: 40$ of 600 s 340 Free gold = 240 - 240 r 0 Credit powers, F. R, notes • x 0 » 0 The hank here has 240 millions of gold in its Vaults hut has to retain it as a 40$ gold reserve upon the 600 millions of Federal re serve notes outstanding, This gold, however, is not a trust fund, it is merely a cash reserve requirement. The amendment provides that this gold reserve of 240 millions may he deposited with the Reserve Agent and still count as reserve, After depositing this 240 millions with the Agent, the account, as shown, supra, under IV/ stood: - Reserve Bank. Federal Reserve Agent. Rediscounts oledeed 600 F. R. Notes 1000 Re d is counts 600 .... " free Gold 400 Capital 400 _ " Total 600 Gold nledeed with Acent 400 •L in vaults of Bank *(400) Total 400 Federal Reserve Notes 400 P.R.Notes 100C .... Total 1400 lood iooc 1400 ♦Held, as per amendment, with the Federal Reserve Agent. Reserve: 40$ of 1000 • 400 Free gold = 400 - 400 : 0 Credit power - Federal Reserve Notes * 2% x 0 *, 0. This shows at' a glance what the amendment accomplishes: Under II, step 2, (present law) the hank paid 160 millions in gold to the Agent which authorized the Agent to issue 160 millions in Federal reserve notes in return for the unpledged discounts which the payment of said 160 millions of gold released. Similarly, under the amendment, the hank pledges this 160 millions for an equal amount of notes. Under the amendment, the hank also pledges the 240 millions of gold held hy the hank under II, step 2, present law, as a reserve against the 600 millions of Federal reserve notes outstanding, and this pledge with the Agent authorized him to issue 240 millions additional of Federal reserve notes making a total of 1000 millions, as against 760 millions under the present law. Under the amendment, however, the 600 millions of rediscounts is pledged as part collateral,--*60$ for 1000 millions of Federal reserve notes, instead of, as in II, Step 2 ,(present law),as 100$ collateral for 600 millions of notes. So also, the lf>0 millions paid to the Agent under II, Step 2 , (present law) remains with the Agent as part collateral for 1000 millions of Federal reserve notes, instead of as 100$ collateral for l60 millions of notes. So also the 2^0 millions of gold, which -was tied up in the hank's vaults as reserve under II, Step 2 ,(Present law), hut which, under the amendment, is pledged with the Agent, stands as part collateral for 1000 mil lions of Federal reserve notes. Thus we see that the amendment has not changed the law as to the requirement of 100$ collateral to he pledged with the Ageni, for we see that the 1000 millions of Federalreserve notes issued hy the Agent are se cured hy 100$, i.e. hy 600 millions of commercial paper, and 1+00 millions of gold. Nor has it changed the law that a reserve of 40$ in gold must he held against outstanding Federal reserve notes, for the required reserve on 1000 millions of Federal reserve notes is U00 millions and we see that there are in the Agent's possession 400 millions in gold which serves as the U0$ reserve, as if actually in the hank's vaults. What change, then has the amendment brought about ? It has simply provided ; (a) that the U0$ gold reserve, if deposited with the Agent, may also count as part of the trust fund of 100$ which the Agent must hold against all Federal reserve notes issued by him. (b) that instead of issuing notes only against commercial paper, the Agent may also issue them against gold* (c) that when the gold pledged for notes amounts to U0$ of the total issue, the gold may serve as the gold Eeserve, or pro tanto, which the hank is required to keep, as.a cash requirement, in its vaults, against such total issue, (d) that the gold reserve is not thus used at the same time for two inconsistent purposes hut is used in the alternative for either of two pur poses, olid, that its use for one releases it from the other. It may be claimed that,hy the amendment the hank is permitted to take out 1000 millions of Federal reserve notes without the necessity . 1118 -38- 631 of carrying ^0$ or ty)0 millions in gold* This, however, is not truo in fact as the gold rosorvo of UOQ mil lions is just as much a cash reserve when held by the Agont as when held if by the bank. What is true, however, is that/HOO millions of gold had boon actually in the vaults of the bank, under the present law, the Agent would have had to hold U00 millions of ccmnereial paper in addition. The proposed amendment releases the Agont from the necessity of carrying this 1+00 millions of commercial paper, by permitting the gold re serve to be held by him in its place. It thus dispenses with the necessity for using ^400 millions of commercial paper but as the bank is assumed to have no commercial paper - other than the 600 millions already pledged with the Agent- no commercial paper in fact has been released to it. On the other hand, if the bank had an ample supply of commercial paper, the amendment would leave in the bank, unpledged, UOO millions of could commercial paper, but the total note is3uec './never exceed 2^ times the amount of gold held by the bank, plus that pledged with the Agent. That tho permission given by the amendment to count the gold reserve against Federal cosorve notes, when deposited with the Agent as part of the Agent’s trust fund, is just, equitable, and in consonance with..sound banking will readily be seen if we consolidate tho accounts of the bank and the Agont, as is really accomplished, at least for Federal reserve note purposes, by the amendment. The account would then 3tand as follows! 5. Consolidated account of Bank and Federal Reserve Agent. Rediscounts Gold Federal Reserve Notes Total Reserve: 600 400 400 1400 Federal Reserve Notes Capital 1000 400 1 1400 * 40# of 1000 c 400 Free gold s 400 - 400 » 0 Credit power, Federal reserve notes * 0. The above shows conclusively that, under the amendment, - (a) the j4gent may issue notes based upon commercial paper or gold; (b) the total jnotes outstanding can never exceed 2^ times the gold in the trust fund, serv-. ing also as a 40$ gold reserve, as if in the bank’s vaults; (c) the notes 631 -39 issued can never exceed 100f» of the total collateral, *■ commercial paper and gold - held by the Agent. VI. Finally, it may be claimed that, assuming that the Amendment is correct work out in theory,yet in practice it would not successfully, for the reason that the bank,-as shown in the statement of account under IV, supra,-is including the gold, - amounting to 400 millions, - deposited with the Agent as part of his trust fund, also as a reserve as if in the bank vaults, whereas it is not in the bank vaults, and the bank has no control over it, and, as a result, if the outstanding 1000 millions of Federal reserve notes, or any portion of them, were presented to the bank for redemption, it would have no gold ac tually in its vaults as reserve for such payment. The answer to this objection is that although the bank does not hold this 400 millions of reserve actually in its vaults, yet it has an immediate right to its possession, which is as good as if it were in its own vaults. 1115 - U 0 - ^31- In this connection it must be remembered that although Federal reserve notes are an obligation both of the Government and of the banks, and must be redeemed by either, the demand for redemption upon one or the other and not upon both. must be made In other -words, the holder of the note on which Mo d d s i r e s redemption must elect whether to present it to the Government or to the bank through which it was issued* If for example, the holder presents it to the Government, the latter must redeem it and.towards this redemption, it has the gold de posited with the Federal Reserve Agent and with the Treasurer, that is the Government has U0$ in gold and must pay also the remaining 60$ which, later, the bank must repay to it. If, on the other hand, the holder elects to from the bank, the latter by paying the not6 demand redemption in full and surrendering it to the Federal Reserve Agent will receive back the gold reserve, leaving its net payment from funds in its vaults, 60$. Thus in either event, the 40$ gold reserve is available to the Government or to the bank, - whichever is called upon to redeem the note; and in either event the bank must pay 60$ of the amount of the note from its cash resources in its vaults and can obtain the 40$ gold reserve for the balance. The only distinction is that if the holder demands redemption from the bank the 60$ aforesaid is paid by the bank to the holder; while if the holder demands redemption from the Government, the 60$ aforesaid is paid by the bank to the Government. 1116 To sum up j 1. The Federal Reserve Bank, in its illustration given . above, by paving the l60 millions of free gold,under the present law, to the Agent, can issue 160 millions additional notes upon which the Govern ment is liable but upon which its liability is "reduced”. 2. The bank by pledging this 160 millions of free gold, under the amendment, with the Federal Reserve Agent, can take out 160 millions ad ditional notes, upon.which it, as well as the Government i3 liable. ' 3. The bank, by pledging the 2^0 millions of gold held, under the present law, in its vaults, as a 40$ reserve against the 600 millions of Federal reserve notes outstanding, of which the collateral i3 commercial paper, can take out 2H0 millions more of notes, as this 2U0 millions of gold will count both as reserve and also collateral for all notes outstanding, thus displacing the necessity for ^00 millions of commercial paper being held by the Agent. 4. The same amount of reserve must be held under the amendment as under the present law, but it may be kept with the Agent and count as part of the 100$ collateral behind the notes. 5* All notes issued must be covered by collateral with the Agent of 100$ in commercial paper, gold or in part,of cash. The real effect of the amendment, therefore is that, whereas under the present law, when the collateral is 100$ commercial paper, a U0$ gold r eserve must be kept by the bank, under the proposed amendment if e. g* U0$ of the collateral is held in gold by the Agent this will dispense with the necessity :ior a gold reserve in the bank's vaults. The effect of the present law, in other words, is to impound in the shape of reserve and collateral, 1^0$ of the value of all notes issued, whereas the proposed amendment dispenses wdth the extra U0$ collateral in the shape of commercial paper, where' at least U0$ of the collateral con sists of gold. V' . 1117 63^ *»U2— This will appear clearly if we were to assume that the lawwere changed so that the office of Federal Reserve Agent were abolished and the accounts of the Agent and the bank were consolidated as in the above illustration* and that the law further provided that the bank could issue Federal reserve notes* provided* it kept in its vaults* as a trust fund for the redemption of the notes* 60$ in comnercial paper and in gold. It is clear* in the above case* that the requirement of a kcrfo cash (gold) reserve against Federal reserve notes would be satisfied if the bank held the r_esult in gold segregated as a trust fund. This is in effect* reached by the proposed amendment* the office of Federal Re serve Agent being retained* but the accounts of the bank- at least for Federal reserve note purposes,- being consolidated with the accounts of the Agent* It i3 submitted that* for the reasons set forth in detail above* the proposed amendment should be enacted into law. Under the law so amended, the Federal reserve banks will be able to conserve gold already in their possession* to secure gold now held by the member banks* e-*" finally* to initiate and maintain an effective and greatly needed National policy of gold conservation. The writor desires to acknowledge tho invaluable assistance rendered in the preparation of this memorandum by Federal Reserve Agent Jay* Mr. Harrison* Mr* Foulk* Mr. Gidney and Mr. Jacobson* 633 STATEMENT FOR THE PRESS i WashingtonApril 29, 1916. The Federal Reserve Board mailed this morning to the Federal reserve banks for distribution to all their member banks its circular announcing a plan for country-wide check clearing and collection* The salient points of the circular are: The Federal Reserve Board, acting under the authority of the Federal Reserve Act, has designated the Federal Reserve Banks to act as clearing houses for the clearing and collection of checks for their members. In doing this the Federal Reserve Board has laid down certain general principles but has left it for the executive officers of the Federal Reserve Banks to work out the details. The Board evidently recognizes the immense amount o£ detail work that must be done in order to put such a vast machinery into smooth operation, and has set the time for beginning the operation of the system as June 15th. The important features of the plan are: (1) The Federal Reserve Banks will accept at par all checks from member banks, whether drawn against other member banks, non-member banks, or private banks. An exception is made at the outset in the case of checks drawn against non-member banks which can not be collected at par, (2) All checks thus received from member banks will be given immediate credit entry, although amounts thus credited will not be counted as reserves, nor become available until collected. (3 ) In order to enable member banks to know how soon checks sent in for collection will be available either as reserves or for payment of checks drawn against them, time schedules, giving the minimum time for collection, will be furnished by each Fed eral Reserve Bank to its member banks. (4) The actual cost, without profit, of the clearing and col lection of checks will be paid by the Federal Reserve Banks and assessed against the member banks in proportion to their send ings . (5) The whole plan is based on generally accepted principles under which clearing and collection plans have long been oper ated. A Federal Reserve Bank will not debit a member bank's reserve account with items forwarded to it for collection until the remittance of the member bank, in payment of such items shall have had time to reach the Federal Reserve Bank. J http://fraser.stlouisfed.org/ I*r Federal Reserve Bank of St. Louis W. P. G. HARDING, GoverNORF* PAUL m . WARBURG. Vice Governor FREDERIC A. DELANO ADOLPH C. MILLER CHARLES S. HAMLIN Ex -O fficio m em bers WILLIAM G. MCADOC SECRETARY OF THE TREASURY CHAIRMAN JOHN SKELTON WILLIAMS COMPTROLLER OF THE CURRENCY FEDERAL RESERVE BOARD H. PARKER WILLIS, SECRETARY SHERMAN P. ALLEN. ASST. SECRETARY AND FISCAL AGENT WASHINGTON ADDRESS REPLY TO *t 6 3 eW tL RESERVE BOARD April 29, 1916. S I R : Referring to our conference and correspondence on the sub ject of check clearing and collection, I have sent you this morning telegram reading as follows : M Clearing circulars are being forwarded to you this forenoon in sufficient quantity to enable you to forward one to each of your member banks. The circulars bear date of May first and we trust will be forwarded with as little loss of time as possible. " Furthermore, I am enclosing, herewith, on behalf of the Federal Reserve Board, copy of the circular sent to you and also copy of the press statement which the Board gave out today. While it may be too much to expect that the Federal Reserve Banks will bo ready on June 15th, it is the hope of the Board that the banks wdLl diligently and energetically take hold of this matter and, through conferences with their member banks and with other Federal Reserve Bank officers, prepare the necessary circulars, instruc tions and forms. The Board's circular, as sent out, embodies many of the criticisms and suggestions that have come to the Board and we believe will prove satisfactory. Respectfully, Vice Governor .1 W. P. G . HARDING, GOVERNOR PAUL M. WARBURG, VICE GOVERNOR FREDERIC A. DELANO ADOLPH C. MILLER CHARLES S. HAMLIN EX-OFFICIO MEMBERS WfLLIAM G. McADOC SECRETARY OF THE TREASURY CHAIRMAN JOHN SKELTON WILLIAMS FEDERAL RESERVE BOARD COMPTROLLER OF THE CURRENCY W A S H IN G T O N H. PARKER WILLIS, SECRETARY SHERMAN P. ALLEN, ASST. SECRETARY AND FISCAL AGENT ADDRESS REPLY TO ^ ly g E R A L RESERVE BOARD May 1,1916 My dear Mr. May I ask you to tell me for the information of the Board, the extent to which you have access to examiners* re ports of National hanks in your district ? It i3 assumed that you now have a complete file of all "condition reports" of hanks in your district for the year and a half since your hank was opened, - say nine reports - and that you also have a list of all hanks that are on schedule for special examina tion, and, in addition to that, at least an abstract by the examiner of his reports to the Comptroller of the Currency. To summarize, the Board wishes to know to what ex tent you feci that you have complete and accurate knowledge of the condition of your member banks, and whether or not you are in a position to decide quickly if you can safely make advances to them on eligible collateral. If you have difficulties in procuring necessary information from the Chief Examiner of your district, please explain what those difficulties are. Yours very truly, Vice Governor. 637 a p r o g n o s t i c a t i o n One feature of the general question of the clearing and col lection of checks is worth pointing out because it has not been re ferred to by writers on the subject,, and that is the strengthening of the bonds uniting the Federal reserve banks and their members which this action by the Board will accomplish. Until now the only member banks having direct communication with the reserve banks were those having occasion to rediscount their paper. This represented in some districts less than ten per cent of the member banks; in none more than one~third. The great majority of member banks have regarded the Federal reserve banks as an emergency provision for which they were pay ing rather dear. The Board's action in designating the reserve banks to act as clearing houses for their own member banks at once establish es a new and far-reaching relationship. Not only will the Federal re serve banks put themselves in a position to render a service to their members which only the largest banks in New York, Chicago and St.Louis have been able to render heretofore, but it seems entirely probable that on a bare cost basis this service will be rendered for less than it ever was before. But in order to protect themselves against the sendings of other banks, each member bank will find it advantageous to send items to its Federal reserve bank sufficient to offset items com ing against it, and if unable to meet the flow of items against it, will find it advantageous to increase its book balances in the Feder al reserve bank, which may be done by remittances, but more naturally as time goes on by discounting short-time paper with the reserve bank. By these features of the check clearing and collection plan the relations of the Federal reserve bank with its members will neces sarily become more intimate, and if, as it is fair to assume, the of ficers of the reserve banks treat their members with the same suavity and sagacity that the officers of large reserve city banks now treat their customer banks, there can be no doubt as to the outcome. Further more, while this service is to be rendered to the member banks at cost, without profit, the rediscounting of paper to create excess balances will necessarily yield a profit to the Federal reserve bank and so help that bank in a normal and natural way to earn dividends for its members. It has been pointed out that the Federal reserve banks exist chiefly to extend credit to their members through the rediscounting privilege, but it is not to be supposed that this credit is to take the form sole ly, nor even chiefly, of note issues; the more common form will un doubtedly be, as time goes on, book credits subject to draft. When this clearing plan 3 hall have been put into operation we shall hear less of the Federal reserve banks acting as emergency institutions; less of their being costly instruments for insurance. Then it will be appreciated that they exist to render a valuable serv ice to their members, every day in the week, every week in the month, every month in the yearl F. A. DELANO. May 1, 1916, 1122 .638 CONDENSED SUMMARY OF THE MEMORANDUM OF CHARLES S. HAMLIN, DATED MAY 1st, SO FAR AS RELATES TO PROPOSED AMENDMENTS TO SECTION 16, OF THE FEDERAL RESERVE ACT, 1. It is necessary carefully to distinguish between: A. The issue of Federal reserve notes.by. the Federal Reserve Agent to. a Federal reserve bank. B. The paying out of such notes by the Federal reserve bank into circulation. 2. The present law requires: For A, - the pledge with the Agent of 1C0$ in commercial paper. For B, - the impounding in the bank vaults of 40$ gold reserve, 3. The proposed amendment permits: As to A, - the pledge with the Agent of gold as well as commercial paper. As to B, - the pledge with the Agent of the 40$ reserve fund. 4. The proposed amendment also provides that the 40$ gold reserve, when pledged with the Agent, shall count as part of the 100$ col-r lateral which the Agent must have as security for all outstand ing Federal, reserve notes, and that it shall be counted, as if it were in the bank vaults, as tho gold reserve of 40$ required to be impounded in the bank*s vaults. 5. The effect of the amendment is: - A. Where the bank has an ample supply of commercial paper. It permits the same issue of Federal reserve notes as under the present law, but releases commercial paper &a collateral by the exact amount of gold deposited with the Agent. B. When the bank can secure only a limited amount of com mercial paper.* It permits the bank to issue a larger amount of Federal, reserve notes by the exact amount, dollar for dollar, of gold deposited in liou of cornnercial paper. 1123 - 2 - 638. In both A and 9, however, the total notes outstanding can never exceed 8^ times the amount of gold held by the bank, whether deposited, as in A, in the bank vaults, or deposited, as in B, with the Federal Reserve Agent, In both A and B, also, the total notes outstanding can never exceed the amount of collateral, whether commercial paper or gold, pledged with the Agent. 6. Under the present law, if the bank has 2f times as much commercial paper as it has free gold in its vaults it can take out as many notes as it could under the amended law, and no special benefit would be derived by the amendment, except that it would permit banks to conserve their gold by taking out Fed eral reserve notes, dollar for dollar, in its place. 7. If, however, the Federal reserve bank can not secure si x as much commercial paper as it has gold, some of its gold can not be utilized in the shape of Federal reserve notes for lack of commercial paper to pledge with the Agent, and the amendment permits the lack of commercial paper to be made up by the pledge of gold in its place, and thus enables all of the gold owned by the bank to be utilized by the issue of Federal re serve notes. 8. The amendment thus permits an additional issue of notes, dollar for dollar, by the amount of gold deposited by the bank with* the Agent, but the total issue can never be (a) more then x the gold held in the bank's vaults (excluding that 2j held as reserve against deposits,) plus the gold pledged with the Agent; (b) more than 100$ of the total collateral, paper and: gold held by the Agent. 9. Thus the amendment operates to reduce the gold and paper required to be impounded from a minimum of 140$ (40$ reserve plus 100$ comnercial paper) under the present law, to a minimum of 100$ (40$ reserve and 60$ comnercial paper) under the amendment. 1124 _ 3 - 10. 638. The 40$ gold reserve, under the present law, when held in the bank's vaults servos as a reserve for 2 ar x that amount of notes covered by 2% x the same amount of commercial paper; when, however, this reserve, when available a3 a basis for further note issues* is deposited with the Agent, .under the amendment, it serves as part collaterali dollar for dollar, for all outstanding Federal reserve notes, and also as the required cash (gold) reserve11. The amendment is, in effect, a legal recognition of the fact that the 40$ cash (gold) reserve requirement when kept in the bank's vaults is not a trust fund, but merely, a cash (gold) requirement; when, however, this cash (gold) reserve is pledged with the Federal Reserve Agent, it becomes a part of his collateral, that is to say, a part of his trust fund., 12. The .amendment, therofore, provides that where 40$ of the Agent's .* trust fund consists of cash (gold).* * - ^ - 1 be held to satisfy the requirement of a 40$ cash (gold) reserve. 13. The amendment, while permitting an increase o f notes to the ex tent that gold is permitted to serve as collateral, produces no inflation, for the reason that all notes issued are covered by 100$, either in commercial paper or gold, or - • both, as a trust fund. 14. As a matter of fact, a contraction necessarily results from the substitution of Federal reserve notes for the outstanding National bank notes, both under the present law and under the amendment, bocause of the 40$ gold reserve required for Federal reserve, notes as compared with only a 5$ reserve for National Bank notes. If such substitution could immediately *\ take place it would more than absorb the 250 millions of net imports of gold into the*United States since January 1 ,. 1914„ 15. The amendment is predicated upon'two principles; 0 (a) That., if 1125 638 - 4 Federal reserve notea can be safely issued by the Government against the pledge of 100$ of eoraBercial paper, it does not impair their safety if they can be issued against 60$ com mercial paper and 40$ gold/ or against 100$ of gold; (b) That the cash (gold) reserve requirement is satisfied by permit ting it to be deposited with the Agent and thus constitute a part of his trust fund. 16. Assuming that the Federal reasrve banks must keep a 40$ gold re serve, it makes no difference whether it is kept in the bank’s vaults or with the Federal Reserve Agent, for, as shown in the memorandum, it is as instantly available to \ the reserve bank in the latter case as in the former. 17. The real effect of the amendment is, therefore, to prevent un 4 necessary duplication of collateral whether considered as reserve or as a trust fund, recognizing that, if in the shape of gold, it is as available for reserve as for col lateral, or as available for collateral as for reserve. It can never be actually used for both purposes at the same time, Its service is an alternative one, and its use for either purpose discharges it from liability for the other, 18. Concrete results of the amendment as to note issuing power. A Present Law Assume that the bank holds 400 millions of free gold which, for convenience, we will call capital. Under the present law it can not directly take out Federal re serve notes against this gold unless it has 2% times this amount in paper. This is to say, while 400 millions of gold held as reserve in the bank’s vaults would sustain am issue of 2a- times 400 millions in notes, i. e., 1000 millions, yet notes to that amount could not be taken out except by the pledge of 1000 millions of paper. 638. o38. . 5 r Only, therefore, in the event that it could radiscouni 1000 millions of paper for member banks, could it use its 400 millions of gold as a reserve for 100 C millions of Federal reserve notes. B If the member banks, instead of offering 1000 millions of paper for rediscount, should offer 1000 millions of gold as an ex cess deposit provided the Reserve banks gave 'them Federal re serve notes, the Reserve banks could not accept the gold for, although such deposit would give them a total of 1400 mil lions in gold, not a single Federal reserve nets could be taken out from the Agent by depositing it, or any part of it. Amended Law Under the amendment, however, the banks in A could take out 400 millions in Federal reserve notes by depositing with the Agent 400 millions in goldj and in B they could take out 1400 mil lions in Federal reserve notes, paying 1000 millions to the member banks, and retaining 400 millions in their cash, thu conserving 1400 millions in all of gold, D Let us suppose that in A above, the Reserve banks can not secure 2t times as much paper as they have in free gold, but can secure, e. g., only 600 millions. In such a case, under the present law the banks could take out only 600 millions of Federal reserve bates directly against the pledge of 600 millions of paper. This would leave the bank with its 400 millions of gold, of which 240 millions is held as reserve for the 600 millions ox Fedora! - 6 r>: reserve notes already taken out, and 160 millions would remain free in its vaults, not capable of being used for further Federal reserve note issues because of lack of com mercial paper to pledge for them. E The bank could, however, - under the circuitous process permitted by the.prassnt law, - pay this 160 millions of free gold to the Agent, taking down 160 millions of paper, and then by repledging the paper obtain 160 millions of additional notes, making the total outstanding notes 760 millions. F The maximum note issuing power, therefore, under the present law, assuming 400 millions of free gold and 600 millions of paper, is 760 millions. G Under the amendment, however, the bank could not only pledge the 160 millions referred to above in E with the Agent, thus receiving 160 millions in notes, but it could also pledge with the Agent the 240 millions of gold held in its vaults as a reserve against the 600 millions of Federal reserve notes secured by pledged commercial paper, and by thus pledg ing this 240 millions of gold, could take out 240 millions additional of Federal reserve notes. The total notes which could be taken out under the amended law, % is therefore, 1000 millions. The Agent would then hold as collateral 600 millions of paper and 400 millions of gold, 4. e., 10 0 $ of all notes issued by him. The required reserve of 1000 millions of notes is 400 millions. Inasmuch as the Agent hold3 400 millions of gold this, under the amendment, satisfies the cash (gold) reserve requirement. '- 7 - D * 638. H la conclusion: **■ 1. . Under the present law, the reserve hanks can only utilize their free vault gold as a reserve against 2# tiroes that amount in notes assured by 2, zh times that amount of commercial paper, Any excess of gold, in their vaults over what is used as reserves, as in A, supra, must lie idle so far as Federal reserve note issues are concerned, 3, Under the circuitous method permitted under the present law, how ever, this excess gold can be used, dollar for dollar, for new issues of Federal reserve notes, 4. Under the amendment, the gold used as a reserve under A, supra, can also be used, by pledging it with the Agent as part col * lateral, thus permitting the issue of additional notes in amount equal to the gold thus pledged, that is, dollar for dollar; Provided, however, that the total notes Issued by the Agent can never exceed the amount of the collateral, whether paper, gold, or both, - pledged. 6. The 40$ gold reserve requirement is satisfied provided the col lateral held by the'Agent consists of gold to the amount of 40$ of the total notes outstanding. 5/5/16. ^ ,f n o W. P . G . HARDING, GOVERNOR PAUL M. WARBURG, VICE GOVERNOR FREDERIC A. DELANO ADOLPH C. MILLER CHARLES S. HAMLIN Ex-O fficio Members WILLIAM G. MCADOC SECRETARY OF THE TREASURY C h a ir m a n JOHN SKELTON WILLIAMS FEDERAL RESERVE BOARD COMPTROLLER OF THE CURRENCY H . P A R K E RR W I L L I S , SECRETARY S H E R M A N P . A L L E N . ASST. SECRETARY AND FISCAL AGENT WASHINGTON AD D R E SS R E P L Y TO FEDERAL RESERVE BOARD May 3, 1916. Federal Reserve Bank, G-entlemen: In connection with the release of United States bonds securing circulation, and similar transactions, it has occasionally happened that a Federal reserve bank desiring to deposit with the Treasurer of the United States an amount not an even multiple of $10,000 has made an independent shipment of currency to the Treas urer for the odd amount, at the same time requesting the Federal Reserve Board to make deposit of the balance in the nearest multiple of $10,000. Some banks, however, have adopted the practice of re questing the Board to make deposit of the exact amount required for the purpose of bond release, and for credit in the Gold Redemption Fund against Federal reserve notes, such additional amount as would bring the total deposit up to an even multiple of $10,000. This method has proved entirely satisfactory. We bring this matter to your attention for such assistance as it may give in handling deposits of odd amounts, in case you are not already following this method. Respectfully, Assistant Secretary. 0 Ex -O ffic io Members CHARLES S. HAM LIN, GOVERNOR FREDERIC A. DELANO, VICE GOVERNOR PA U L M .WARBURG W. P. G. HARDING ADOLPH C. M ILLER W ILLIAM 6 . McADOO S ecretary of the Treasu ry CHAIRMAN JOHN SKELTON W ILLIAM S Co m p t r o l l e r o f t h e Cu r r e n c y FEDERAL RESERVE BOARD H . PARKER W IL L IS , SECRETARY S H E R M AN 'P^ALLE N , ASST. SECRETARY ADDRESS REPLY TO W ASHING TON FEDERAL RESERVE BOARD May 3, 1916. To State Member Banks: The Federal Reserve Board and the Comptroller of the Currency have agreed upon and now promulgate the following rules in regard to the periodical Reports of Condition which the State member banks of the Fed eral Reserve System are required to render under the provisions of the Federal Reserve Act: 1. WHEN THE REPORTS OF CONDITION MADE TO THE STATE BANKING DEPART MENTS ARE RENDERED AS OF THE SAME DATE AS REQUIRED BY THE COMPTROLLER OF THE CURRENCY FOR NATIONAL BANKS: N (a) The Comptroller of the Currency will accept the reports so rendered by the State banks, on the same forms used in reporting to the State Banking Departments. (b) The publication of reports will be accepted by the Comptroller of the Currency on the publication form rendered to State Banking Departments. provided, the office of the Comptrol ler of the Currency is furnished with proof of publication in the manner required of National Banks. (c) State member banks will be furthermore required to furnish the Office of the Comptroller of the Currency, for abstracting purposes only, a statement of Resources and Liabilities on the form prescribed by the office of the Comptroller of the Currency for National Banks. This statement must be signed by the President or Cashier of the reporting bank and acknowledged before a notary public. 2. WHEN REPORTS TO STATE BANKING DEPARTMENTS ARE NOT REQUIRED TO BE RENDERED ON THE SAME DATE AS REPORTS CALLED FOR BY THE COMPTROLLER OF THE CURRENCY FROM NATIONAL BANKS: (a) State member banks will be required to execute their reports on the same form prescribed by the Comptroller of the Currency for National Banks, but omitting from their report blank, if they so desire, all schedules except that relating to coin and coin certificates, (b) They will also be required to conform to the regulations govern ing National Banks in the matter of publication of reports and the furnishing of proof of such publication. V -2- 640. These rules may be revised or revoked on 30 days’ notice from the Federal Reserve Board or the Comptroller of the Currency, CHARLES S. HAMLIN, ^ Governor, Federal Reserve Board JOHN SKELTON WILLIAMS, Comptroller of the Currency, SHERMAN ALLEN, Assistant Secretary 64a May 5, 1916. STATEMENT BY MR* WARBURG: Secretax^r M c A cloo, the Chairman of our delegation, has nade a very complete statement concerning the work done by the con ference same. at Buence Aires, and X do not see what I could add to the In an address which I made at Buenos Aires I said that the American delegates considered themselves as "exchange professors", and that, while we nad come to contribute our own share m imparting knowledge and fact3 peculiar to our own country, wo realized a t (the same time that we might render a greater service by employing tho time spent in foreign countries m take h^rna to our own country m absorbing knowledge which we would order to make it available to our people. This does net apply to our own delegation only, but with equal force to those of all South and Central American nations. There is no doubt that more Argentinos have crossed the Atlantic than the Andes, and between the majority of the Latin American sister re publics there is hardly any commercial or intellectual intercourse. These conferences are, therefore, productive of the greatest good in promoting mutual understanding among American nations and in devel oping the consciousness of our common interests and ideas, . If by my own impressions I may judge the effect that this conference must have produced on the delegates of all nations, if they learned as much about how " the other man lives " as I learned about them, I could only wish that the " Tennessee" might have carried a thousand delegates instead of seven. 1132 643 -3~ Now that we have returned homo it will be tho duty of us seyen to make over impress ions available to our country. Unfortunately, however, no matter how hard we may try, a good .deal of the intensity of our impressions will1bo lost in trans mission, After w o rapid a visit it will indeod be a difficult undertaking to reproduce the impressions that wc havo received concerning the physical and economic conditions of the various countries, but it will be quite impossible r. task to attempt to reproduco tho improssions made upon us-by some of the eminent men we mot, who won our esteem, friendship and admiration.Some of the countries through which we passed have difficult problems to face, duo to or accentuated by the European upheaval, but h^rd times will provo useful taskmasters, and in some countries we found that difficult problems had produced strong men whose sincerity and ability could not but inspire a confident reliance that their country's fate was in good hands and ultimately would be-worked out successfully. Almost all of these countries offer wonderful possibi lities, and for us who have gained so much through Europe•& losses, it is not only a tempting opportunity, but also a serious obligation placed upon U3 by Destiny - to lend a helping hand to our Latin American sister republics in developing their marvelous resources, and with that their own financial and political independence. I was delighted to see strong evidence of the awak ening of the American spirit of enterprise in almost all the coun tries through which we passed ; oping of ore lands in Brazil , be it in railroading and devel or packing houses in Uruguay 1133 1134 - SU2 3- and Argentine - where tho opening of thoue plants has brought about a great m c r o p s e 1.1 th p n e ^ secured. by tho cattle rais ers of those countries - or be it m or raising sugar -r tobacco m mining in Chile and Cuba* It was a great satisfaction for me to notice in those countries the beneficent effect of our n«/v banking legislation. It did my hoart good to see American banks operating in these foreign citio3, and to find that the American banker*s accoptanco at last haa become an integral part of the world*3 banking machinery. Much remains, however, xo be done m t m s respect. A world markot for tr-ese acceptances has been picvidod, but too many American importers appear to be bight asl9op and do not yet realize That it is poor business for thon to pay a British banker an acceptance commission and a discount rate of abojt five per cent, when by arranging for American bankors* credit they can secure a discount raxo of but two per cent. Tvhen passing through the Panama Canal, I had the great honor of meeting General Gocthals, and I said to him that sha.cing hand3 with n*» gavo me a peculiar thrill, because I felt that the Panama Canal and tho Federal Reserve Act were the two moit constructive contributions made our generation- or the United States in The Panama C«rnal and tho Fecsral Reserve Act have blasted tho \/ay wide open for the development of North. American enterprise, but the businos- that is to floif through these channels must now be developed by the individual initiative of the people of the United States. 1135 -UHowever, if wo aro to socuro our position m 6te tho worlds all legislative obstructions that still stand in tho way of a froo unfolding of our economic powers must be removed, and I sincerely hope that Congress vail not delay the passing of such amendments to tho Federal Reoorvo Act as are necessary in nrder to place our banks on a par with the important Europoan banking institutions m t h which they have to compete m foreign countries. Only tho3j who with thoir own eyoa have seon actual conditions can roalize the importance of securing those changes and of securing thorn promptly. May 5 * 1916 645 A BILL To amend the Act approved December twenty-third, nineteen hundred and thirteen, known as the Federal Reserve Act, BE IT ENACTED BY THE SENATE AND HOUSE OF REPRESENTATIVES OF THE' UNITED STATES OF AMERICA IN CONGRESS ASSEMBLED, That section twenty-five of the Act approved December twenty-third, nineteen hun dred and thirteen, known as the Federal Reserve Act, be amended to read as follows: Sec. 25. Any national banking association possessing a capital and surplus of $1,000,000 or more may file application with the Federal Reserve Board, for permission to exercise upon such conditions and under such regulations as may be prescribed by the said board, either or both of the following powers! First. To establish branches in foreign countries or depen dencies or insular possessions of the United States for the fur therance of the foreign commerce of the United States, and to act if required to do so as fiscal agents of the Unites States. in the aggregate Second. To invest an amount not exceeding/ten per centum of its paid-in capital stock and surplus in the stock of one or more banks or corporations chartered or incorporated under the laws of the United States or of any State thereof, and princi pally engaged in international or foreign banking, or banking in a dependency or insular possession of the United States either directly or through the agBncy, ownership, or control ±1 3 ? -2 - 6H5 of local institutions in foreign countries, or in such dependoncios or insular possessions* Such application shall specify the name and capital of the banking association filing it, the powers applied for, and the place or places where the banking operations proposed are to be carried on. Tho Federal Reserve Board shall have power to approve or to reject such application in whole or in part if for any reason the granting of such application is doomed inex pedient, and shc.ll also have power from tine to timo to increase or decrease the number of places where such banking operations may be carried on. Every national banking association operating foreign branches shall be required to furnish information concerning the condition of such branches to the Comptroller of the Currency upon demand, and every member bank investing in the capital stock of banks or corporations described under sub-paragraph Second of the first paragraph of this Section shall be required to fur nish information concerning the condition of such banks or cor porations to the Federal Reserve Board upon demand, and the Fed eral Reserve Board may order special examinations of the said branches, banks, or corporations at such timo or tines as it • may deem best. Before any national bank shall be permitted to purchase stock in any such corporation, the said corporation shall enter -3- 6U5 into an agreement or undertaking with the Federal Reserve Board to restrict its operations or conduct its business in such manner or tinder such limitations and restrictions as the said board nay prescribe for the place or places wherein such business is to bo conducted* If at any time the Federal Reserve Board shall as certain that the regulations proscribed by it are not being com plied with* said board shall be authorised and shall have power to institute an investigation of the matter and to send for per sons and papers, subpoena witnesses and adninistor oaths, in order to satisfy itself as to the actual nature of the trans actions referred to. Should such investigation result in estab lishing tho failure of the corporation in question, or of the national bank or banks which may be stockholders therein, to comply with the regulations laid down by the said Federal Reserve Board, such national banks may be required to dispose of stock holdings in the said corporation upon thirty days1 notice, and in the event of their noncompliance with such order the Federal Reserve Board may direct tho Comptrolis r of the Currency to in stitute proceedings for forfeiture of charter. Every such national banking association shall conduct tho accounts of each foreign branch independently of tho accounts of other foreign branches established by it and of its hone office, and shall at the end of each fiscal period transfer to its general lodger tho profit or loss accruing at ee.ch branch as a separate item 1139 --4- 6U5 Any director or other officer,, agent or onployoo of any member hank, nay with the approval of tho Federal Roserve Board, ho a director or other officer, agent, or onployse of any such hank or corporation above nontioned, in the capital stock of which such monte r hank shall have in vested as hereinbefore provided, without being subject to tho provisions of Section 8 of tho Act approved October 15, 19lU, entitled "An Act to supplement existing laws against unlawful restraints and monopolies, and for other purposes." 5/9/16 646. Washington, D. C., May 10, 1916. COMMENTS ON GOVERNOR HAMLIN’S BRIEF ON THE UOTE ISSUE AMENDMENTS. • This is a very able, thorough and painstaking document and I would not like to have anything I say appear to show any lack of appreciation of it. I believe, however, that.it is based upon some misconceptions which should be pointed out. * (1) I think there is a confusion of ideas as to the relations of two things which are not similar, but totally dissimilar; that is to say, there is a confusion between the "collateral security" for a credit given, and loan made, whether that loan be in the form of a deposit or in the form of a payment of currency, or issue of bank notes, on the one hand and the reserve which a bank is required by law to retain against either deposits or note issues on the other. (2) Governor Hamlin’s brief states in a good many different ways that the only gain in the 40 - 60 proposition is in the release of 40$ of paper for use as collateral. He admits that just as much gold is used for note issues under the old plan and could be under the proposed plan; hence, that with a given amount of gold we can issue no more notes under the new plan than under the old. What he points out very clearly is that a bank with a limited supply of eligible paper could issue a good many more notes with a given supply of gold under the new plan than under the old. I believe Governor Hamlin is entirely right in this contention and it leads me to make inquiries regarding two things: sue *-2~ (a) Considering the fact that we are proposing to en large the field of eligible paper by admitting acceptances bought in the open market when bearing member bank endorse ments, why should we fear that there will not be enough elig ible paper ? (b) When a member bank calls on a Federal Reserve Bank for notes it presumably offers a quid pro quo of at least 1. 100# on the dollar, henco , it is inconceivable that when there is a demand for currency by member banks, the member banks will not be ready to offer eligible collateral for the currency, especially, if we enlarge the field of eligibility which we may do both by an amendment of the law and by a relaxation of our Board rules in time of stress. (3) I am thoroughly in accord with the idea of combining the assets and liabilities of the bank and of the Federal Re serve Agent. However, I am not at all sure that this can not be done under the Federal Reserve Act as it stands. think we ought to get an amendment. If not, I My theory is that the Federal Reserve Board can publish condition reports of the banks, stating that they are combined statements of the Federal Reserve Banks and the Federal Reserve Agents, treating the Federal Reserve Agent’s Department as if it were simply the Issue Division of the Federal Reserve Bank. I agree entirely that 3 - 645 it is all wrong that if a ten millions of Federal Reserve notes are put out against commercial paper, and at the end Of a three months' period is all paid off, although the notes continue to stay in cir~ culation, the notes should no longer appear as the liability of the bank. It seems to me obvious and proper that the outstanding notes should appear as a liability of the bank and, per contra and as an offset, the cash or collateral held against these notes ought to be written up as an asset. (4) A fundamental proposition which seems to me must never be forgotten and, therefore, should perhaps be re-stated is that the relation of the member bank to the Federal Reserve Bank is similar in general terms to the relation of an ordinary individual, or corporation, to a commercial bank, having note issuing power. The member bank comes to the Federal Reserve Bank to borrow credit. It may need that credit in the form of a bank deposit, or in the form of currency. If it takes it in the form of a bank deposit, it may later draw out the currency, or, more likely, it will use it to meet drafts upon it for transfers to other banks in other cities. A member bank coming to the Federal Reserve Bank to borrow a million dollars, in effect, gives its note to the Federal Reserve Bank, with eligible collateral attached, for the full face value of its borrowing 6h6 -U . t and if we assune the Federal Reserve Agent's Department is part of the bank, the bank nu$t keep this collateral against the loan. Aside and apart from this, however, the Government which charters the Federal Reserve Bank, says to that bank, and as a condition precedent to its charter rights, " In order to compel you to be cautious and conservative, we will require you to keep a reserve against all deposit liability of 35$ a&d against all note issue 4 liability of U0$." This is a matter between the Government and the Federal Reserve Bank. The 35$ and the Uo$ cannot be considered in any sense as added collateral against either the deposits the notes. or It is so lely Government regulation to accomplish two purposes : First, to guarantee a reasonable amount of cash in bank to quickly redeem notes that may be presented, or repay deposits, which may be called for, and, secondly, a condition which 'will compel a bank, which is in the fullest sense a public service corporation, to run its business on lines of extreme Conservatism. If the above statements are correct, it isn't readily conceivable that a member bank will ever find itself in a place where it has not enough collateral from member banks to meet legitimate demands for currency, and certainly, if we wish to create a good discount market in this country, we ought to do everything we can to encourage member banks to keep in their portfolios an abundant supply of eligible • paper* It is far better to liberalize the law in respect to the character of the paper Which may he offered by member bariks, or to let down the bars so far as our rules are concerned, than it is to weaken the fundamental provisions of the law in respect to giving the credit by Federal Reserve Banks (5) Governor Hamlin cites the case of the panic of 1914, and previous panics, showing that simultaneously with the rapid dimunition in business, there was an active demand for currency. He assumes, therefore, that if these conditions should arise, the Federal Reserve Banks might find themselves unable to meet demands for currency and be compelled to weaken their cash resources by issuing the stock of gold on hand. This is an important point and should be carefully studied. In the panics of 1907 and 1914, and indeed, as I understand it in pre vious panics, what happened was that bank deposits were very largely pyramided by reason of the reserve city and central reserve city system so that St. Louis, Chicago and most of all New York, held a large pro portion of the bank deposits. Two things which brought about this evil were, first, that deposits could be counted, as reserves, in two places; second, that interest was paid upon deposits. The first of these evils has boon cured by the Federal Reserve Act; the second still remains, as a more or less serious evil. If the Federal Re-serve Banks paid interes GkS -6 ~ on reserve deposits^or even on excess deposits only* we might increase to this evil,, but, as we do not do so, so far as de posits of the Federal Reserve Banks are concerned, the evil is non-existant. Thus it is that no member bank will keep on deposit with the Federal Reserve Bank a deposit in excess' of its actual requirements* This will mean that they will keep a minimum reserve requirement, plus... sufficient to meet their own needs to pay their own drafts or checks and drafts against them. Hence, in the panicky times you will not have the condition that you had in 1907 and I91U. Thon country banks were calling on reserve city banks for cash, reserve city banks on central reserve city banks, and the very fact that there was a reluctance to meet these demands accentuated them and increased the alarm. Banks began calling loans, stopped making new ones, or quickly raised their interest rates. this This naturally put a sharp check on business. While same thing can happen again to a limited extent, es pecially if a large proportion of the state banks stay out of the System and if interest paid on bank deposits causes the pyramiding of money at the large money centers, yet because a large share of the reserves of the country are held by Federal Reserve Banks, the evil possibilities from this cause has been greatly diminished. (6) A number of Governor Hamlins calculations are bas&d on the assumption of what he rails ,rfree gold", or 546. - 7 as he suggests in his assumption "capital”. These assumptions, lead. 6ne astray because they are contrary to certain fundamental facts* The only !'free gold" in the Federal Reserve Bank System that I know of is the capital paid in by the members, approximately $55,000,000, for although there is a liability against this, the law does not require any reserve to be held to protect it. The capital can therefore be used on the basis of 2'k times as a re serve for notes issued. In addition to this capital, the princi pal fund of the reserve banks amounts, in round figures, to $450,* 000,000, and will be about $500,000,000 after the 16th of May. Against this reserve deposit, however, there must be kept 35$ of reserve/ and only the remaining 65$ can be used as a reserve against note issuing. Thus the note issuing expansion for the reserve deposit fund is upon the ratio of 1*625 to 1; not 2.5 to 1. It may be argued that this is ultra-conservative, but I believe it is proper, and we should leave it that way* in time of stress it would be better for the Board to reduce its reserve requirements than to treat this reserve deposit, to use Goverhor Hamlin’s expression, as "Free gold". In conclusion, there are three amendments, to Section 16 which are immediately desirable: * 8 - First: 646 It ought to be possible to issue Federal Reserve notes directly for gold. It is conceivable, for example, that at some future date, the Government will stop the coinage of gold, or only use gold bars and issue certificates for amounts not less than fifty or one hundred dollars against them; that hoiders of these gold bullion certificates may frequently be glad to deposit them with the Federal Reserve Bank and get currency in more con venient denominations. This ought to be possible and when a Federal Reserve Bank holds gold against its notes it should not be required, considering the character of its collateral^ to catty any reserve against it. Second: If it is not possible under a fair interpretation of the existing law to combine the accounts of the Federal Reserve Agents and the Federal Reserve Banks, so as to show all notes in the hands of the public as a liability of the issuing bank and all assets held against them as collateral as assets of the bank, then we should recommend such an amendment of the law as would permit it. Third: We should ask for an amendment of the law which will permit bank acceptances, or paper bought under Section 14, of the Act, when accepted or endorsed by a member bank, to be made eligible as collateral for Federal Reserve notes. This will not only very much increase the volume of paper which will be eligible for re discount but willsassist in building up our discount market. 646 - 9 The above three amendments, I believe, are the only amend ments which it is necessary, or desirable, to make to Section 16 at the present time. Later on, 1 believe, at least one other amendment should be made, ana that is looking toward the consoli dation of the note issuing functions of the Federal Reserve Banks. It is very undesirable that there should be two kinds of notes issued by the Federal Reserve Banks. The re should be only one kind and that a Federal Reserve Bank note. If that idea should meet with the approval of my colleagues and the Congress, the Federal Reserve Banks would issue notes upon any of the following plans: (a) For gold bullion, (b) Upon the note of a member bank, having behind it eligible commercial paper as collateral, (c) Against the collateral of Government bonds, having the circulation privilege. If this were done, in case (a) no reserve would be required of the Federal Reserve Bank. In case (b) a reserve of at least 40$ would be required unless the Federal Reserve Board should reduce the requirement. In case (c) a reserve of 5$ would be required. If this great reform were adopted, I should perhaps go a step further and suggest that the elaborate, costly and compli cated machinery of the United States Government in Washington for refunding notes should be abolished, and that, 646 -1 0 - in the place of it., the Federal Reserve Bank notes should he made redeemable only at the counter of the Federal Re serve Bank of issue under the supervision and rules of the Federal Reserve Board. F. A. DELANO. 6/lO/l6 6Us(a; That section sixteen* paragraphs two,threerfour,five,six and seven., of the Act approved -December twenty-third, nineteen “hundred and thirteen, known as the Federal Reserve Act, as amended by the Act of September 7 4 1 9 1 6 , be further amended and re-enacted so as to read as follows: "Any 'Federal reserve bank may ma&a application to the local Federal reserve agent for such amount of the Federal reserve notes hereinbefore provided for as it ir.ay require. Such application shall be accompanied with a tender to the Local Federal reserve agent of collateral in amount equal to the sum of the Federal re serve notes thus applied for and issued pursuant to such applica tion. The collateral security thus offered shall be notes, drafts, bills of exchange, or acceptances rediscounted under the provisions of Section thirteen of this Act, or bills of exchange indorsed by a member bank of any Federal reserve district and purchased under the provisions of Section fourteen cf this Act, or b?jikers' accept ances purchased under the provisions of said section fourteen)! OR GOLD OR GOLD CERTIFICATES;‘ BUT IN NO EVENT SHALL SUCH COLLATERAL SECURITY WHETHER GOLD, GOLD CE:TIFICATES, OR ELIGIBLE PAPER, BE LESS THAN ; THE AMOUNT OF FEDERAL RESERVE NOTES APPLIED FOR. The Federal re** serve agent shall each day notify the Federal Reserve Board of all issues and withdrawals of Federal reserve notes to and by the Feder al reserve bank, to which he is accredited. The said Federal Reserve .Board-may at any time call upon a Federal reserve bank for addition al security to protect the Federal reserve nctes issued to it.•'Every Federal reserve bank shall maintain reserves in golf or lawful money of not less than thirty-five per centun against it? deposits and reserves in gold of not less than forty per centum against its Federal reserve notes in actual circulation- PROVIDED, HOWEVER THAT WHEN THE FEDERAL RESERVE AGENT HOLDS GOLD OR GOlp CER TIFICATES AS COLLATERAL FOR FEDERAL RESERVE NOTESTISSUED TO THE EANK SUCH GOLD OR GOLD CERTIFICATES SHALL BE COUNTED AS PART OF THE . GOLD RESERVE WHICH SUCK BANK IS REQUIRED TO MAINTAIN AGAINST ITS FEDERAL RESERVE NOTES IN ACTUAL CIRCULATION aad net aitset by geld o f lawful meaey deposited with the Federal reserve agent. Notes so paid out shall bear uppn th6ir fades a distinctive letter and serial number, which shall be assigned by the Federal Reserve Board to each Federal reserve bank. Whenever Federal reserve notes issued through one Federal reserve b^nk shall be received by another Federal reserve bank they shf ?.ll be promptly returned for credit or redemption to the Federal reserve bank through which they- were originally issued, OR, UPON DIRECTION OF SUCH FEDERAL RESERVE BANK THEY SHALL EE FORWARDED DIRECT TO THE TREASURER OF THE UNITED STATES TO BE RETIRED. No Fed eral reserve bank shall pay out notes issued through another under penalty of a tax pf ten per centum upon the face vaLue of notes so paid out. Notes presented for redemption at the Treasury of the United Stages shall be paid out of the redemption fund and returned to the Federal reserve banks through which they were originally issued, and thereupon such Federal reserve bank shall, upon demand of the Secretary of the Treasury, reimburse such redemption fund in lawful money, or, if such Federal reserve notes have 1151 648 -2 - been redeemed by the Treasurer in gold or gold certificates, then such funds shall be reimbursed ta the extent deemed neces sary by the Secretary of the Treasury in gold or gold certificates, and such Federal reserve banks shall, so long as any of its Federal reserve notes remain outstanding, maintain with the Treasurer in gold an amount sufficient in the judgment of the Secretary to pro vide for a ll redemptions to be made by the Treasurer. Federal re serve notes received by the Treasurer, otherwise than for redemp tion, may be exchanged for gold out of the redemption fund herein after providod and returned to the reserve bank through which they were originally issued, or ittof may be returned to such bank for the credit of the United States. Federal reserve note3 unfit for circulation shall be returned by the Federal reserve agents to the Comptroller of the Currency for cancellation and destruction. nThe Federal Reservo Board shall require each Federal reserve bank to maintain on deposit in the Treasury of the United States a sum in gold sufficient in the judgment of the Secretary of the Treasury for the redemption of the Federal reserve notes issued to such bank, b\*t in no event less than five porcentum OF THE TOTAL AMOUNT OF NOTES ISSUED LESS THE AMOUNT OF GOLD OR GOLD CERTIFICATES HELD BY THE FEDERAL RESERVE AGENT AS COLLATERAL SECURITY; but such deposit of gold shall be counted and included as part of the forty percentum reserve hereinbefore required. The Board shall have the right, acting through the Federal reserve agent, to grant in whole or in parj or to reject entirely the ap-. plication of any Federal reserve bank for Federal reserve notes; but to the extent that such application may be granted the Feder al Reserve Board shall, through its local Federal reserve agent, supply Federal reserve notes to the bank so applying, and such bank shall be charged with the amount of notes ISSUED TO IT and shall pay such rate of interest e» said amount as may be estab lished by the Federal Reserve Board and the amount ef ON ONLY THAT AMOUNT OF SUCH NOTES IBICH EQUALS THE TOTAL AMOUNT OF ITS OUT STANDING FEDERAL RESERVE NOTES LESS THE AMOUNT OF GOLD OR GOLD CERTIFICATES HELD BY THE FEDERAL RESERVE AGENT AS COLLATERAL SE CURITY. Federal reserve notes ae issued to any such bank shall, upon delivery, together with such notes of 3uch Federal reserve bank as may be issued under section eighteen of this Act upon se curity of United States two percentum Government bonds, become a first and paramount lien on all the assets of such bank. Any Federal reserve bank may at any time reduee its liability fer outstanding Fed^sfal ffeer-rvb''netes ^ de positing with the Federal reserve agent its Federal reserve i 1153 -648■ -3 - netee, geld,geld eeFtifieates,- e r lawful »:eney ef the United States, Federal reserve **tee ee deposited shall net he reissued, exeept upen eemplianee with the eenditiens ef an original issue. The Federal reserve agent shall held sueh geld, geld certi ficates er. lawful ueaey available exelu&iuely fer exchange fer the out standing Federal reserve aetes when offered by the reserve bank ef whleh he is a direeter. Uj.cn the request of the Secretary oi the Treasury the Federal Reserve Board shall require the Federal reserve agent to trans mit ee i&uth ef the paid geld to the Treasurer of the United States SO MUCH OF. THE GOLD HELD BY HIM AS COLLATERAL SECURITY FOR FEDERAL RESERVE NOTES as may be required for the exclusive purpose of the redemption of of such notes FEDERAL- RESERVE NOTES BUT SUCH GOLD ’ WHEN DEPOSITED WITH THE TREASURER SiiAT.T- BE c m i E D AND CONSIDERED 4S IF .COLLATERAL SECURITY ON DEPOSIT WITH THE FEDERAL RESERVE.AGENT. Any Federal reserve bank may at its discretion withdraw collateral deposited with the local Federal reserve agent for the pro tection of.its Federal reserve notes depesited with it ISSUED TO IT and shall at the same time substitute therefor other lake collateral of equal amount with the approval of the Federal reserve agent under regulations to be prescribed by the Federal Reserve Board. ANY FEDERAL RESERVE BANK MAY RETIRE ANY OF ITS FEDERAL RESERVE NOTES BY DEPOSITING THEM WITH THE FEDERAL RESERVE AGENT OR WITH THE TREASURER 07 THE UNITED SPATES, AND SUCH FEDERAL RESERVE BANX SHALL THEREUPON BE ENTITLED TO RECEIVE BACK THE COLLATERAL DEPOSITED WITH THE FEDERAL RESERVE AGENT FOR THE SECURITY OF SUCH NOTES. FEDERAL RESERVE BANKS SHALL NOT BE RE QUIRED TO MAINTAIN THE RESERVE OR THE REDEMPTION FUND HEP.ETGFORE PRO VIDED FOR AGAINST FEDERAL RESERVE NOTES WHICH HAVE BEEN RETIRED;NOR SHALL THEY BE FURTHER LIABLE TO PAY ANY INTEREST CHARGE WHICH'MAY HAVE BEEN IMPOSED THEREON BY THE FEDERAL RESERVE BOARD. FEDERAL RESERVE NOTES SO DEPOSITED SHALL NOT BE REISSUED EXCEPT UPON COMPLIANCE WITH THE CONDITIONS OF AN ORIGINAL ISSUE. 655. F E D E R A L R E S E R V E W A S H I N G B O A R D TO N May 15, 1916. Memorandum for the Board: As requested, I have made a brief analysis of the provisions of the Federal Farm Loan Act, as it passed the Senate. This Act was referred to the Banking and Cur rency Committee of the House, and the Committee's report appears to be a substitute bill which will have to be made the subject of a separate analysis in order to show the changes made in the substance of the Senate bill* 1 assume that the Board will desire this analysis after the House Bill has been passed. In analyzing the Senate Bill I have not attempted to outline all the details of operation, but merely to show the fundamental provisions and the general plan of operation. Respectfully, M. C. ELLIOTT, Counsel. a n a l y s i s o f f e d e r a l f a r m l o a n a c t as PASSED BY THE SENATE. * * * May 12, 1916. THE FEDERAL FARM LOAN BOARD. The Act provides for the creation of a bureau in the De partment of the Treasury to be known as the Federal Farm Loan Board which consists of five members including the Secretary of the Treas ury, who is made an ex-officio member and chairman. pointed members receive salaries of $10,000 each. The four ap All salaries and expenses are paid out of the general funds of the Treasury. This board is authorized to employ attorneys, experts,etc., in the same manner as the Federal Reserve Board. not under civil service. The employees are It makes an annual report of its operations to Congress. Its general powers, as summarized in Section 20 are sub stantially as follows: (a) To organize and charter Federal land banks, national farm loan associations, and joint-stock land banks. (b) To review and alter at its discretion the rate of interest to be charged by Federal land banks. (c) To authorize the issue of farm loan bonds, (d) To make rules and regulations respecting charges made to borrowers on loans, for appraisal,examining titles,etc. (e) To require reports of condition and to make examinations. (f) To prescribe the form and terms of farm loan bonds. (g) To require Federal land banks to pay to other Federal land banks their equitable proportion of sums ad vanced to pay the coupons on bonds issued by such banks. 655. - 2 - (h) To exercise general supervision over (1) (2) (3) Federal land banks,, National farm loan associations, Joint-stock land banks. FEDERAL LAND BANKS. The Federal Farm Loan Board is empowered to divide the continental United States into twelve districts to be known as Federal land bank districts to be designated by number, and to create and organize in each district a Federal land bank with a capital stock of not less than $500,000. Board of Directors: A temporary board of five directors is appointed by the Federal Farm Loan Board during the preliminary organization of these banks. This board is later replaced by a board of five directors, three of which are elected by the farm loan associations and two are appointed by the Federal Farm Loan Board, one of the two so appointed being designated aS chairman. Capital Stock: If, within ninety days after the sub scription books are opened, anf part of the minimum Capitalization of $500,000 has not been subscribed, by individuals, firms or cor porations or by the States, the Secretary of the Treasury is re quired to subscribe for the balance on behalf of the United States. This subscription, however, is later repaid to the United States when a sufficient amount of stock is sold to other subscribers. Ten per cent of each $100,000 worth of stock subscribed is in vested in bonds of the United States not later than two years after the payment of such subscription. These banks may act as Government depositaries and fiscal - 3 - 655 agents of the Government. P ow ers: They are giv e n the u s u a l co rp o ra te powers and. among others the following special powers: (1) To issue farm loan bonds; (2) To purchase first mortgages on farm lands within the district; (3) To deposit first mortgages with a registrar as security for farm loan bonds; (4) To receive and set apart for expenses and profits one per cent interest on endorsed mortgages; (5) To acquire and dispose of real and personal property under certain conditions; (6 ) To make deposits with Federal reserve banks or member banks and to receive interest on the same; (7) To receive deposits from farm loan associations, but not to pay interest thereon; (8 ) To borrow money; (9) To buy and sell United States bonds. Restrictions: Such banks are not permitted * (1) To accept ordinary demand deposits except from its stock holders; (2 ) To make loans on farm taortga.ges except through farm loan . associations; (3) To accept other than first mortgages; (4) To issue bonds in excess of twenty times the amount of its capital and surplus; (5) To receive any commission or charge not authorized by the Act. NATIONAL FARM LOAN ASSOCIATIONS. These associations are organized by persons desiring to borrow money on farm mortgage security. Their directors are elected in the same manner as national bank directors. Their officers., other than the Secretary-Treasurer, serve without pay, unless the Federal Farm Loan Board approves a salary. The Secretary-Treasurer acts as custodian of its funds depositing same in such banks as the board of directors may designate; pays over to borrowers sums received for their account from the Federal land banks upon first mortgages, and is the active officer of the association. Subscribers; The incorporators of such an association must consist of ten or more natural persons who are the owners or who are about to become the owners of farm land, qualified as security for a mortgage loan. They execute an organization certifi cate which is submitted to the Federal land bank, and, acting upon the recommendation of the Federal land bank, the Federal Farm Loan Board issues a charter. The loan desired by each subscriber must not exceed $10,000 nor be less than $200, end the aggregate must not be less than $20,000. The borrower must subscribe to stock in a sun equal to five per cent of the desired loan. These associations may be organized with limited or with unlimited liability. The capital stock is issued in shares of $5 each to borrowers, and this stock is held by the associations as collateral security for the loan made, but the borrower may receive dividends accruing and payable on such stock, and when the loan is repaid the stock is canceled and the subscription is repaid or it may 655 5 be credited on the loan when the balance has been paid. The capital stock of these associations may be increased from time to time -as additional loans are desired, and may be reduced to any sum not less than five per cent of the unpaid principal of mortgages held. The special powers of these associations consist of the right (1) To indorse and to discount with Federal land banks first mortgages; (2 ) To receive from such banks funds to be loaned to its shareholders; (3) To acquire and dispose of real and personal property under certain conditions; (4) To issue certificates of deposit at four per cent per annum againsi deposits or current funds, conver tible into farm loan bonds when presented at the Federal land bank of the district in any multiple of $25. This stock carries with it the double liability of share holder. In the unlimited farm loan association the subscriber enters into a contract to become individually liable for all con tracts, debts, and engagements of the association’in addition to his liability on the stock. Loans Made by Federal land banks: Loans made by Federal land banks are subject to the following restrictions: (1) They must be secured by first mortgages on fann land located in the district; (2 ) Each mortgage must contain an agreement for repayment under the amortization plan; (3) They must run for not less than five nor more than sixty years; (4) Payment may be anticipated by the borrower on interest payment periods at any time after five years; -6- 655 (5) Interest rate limited, to six per cent. (6» Loans may be (a) For (b) For (c) For (d) For (7) Loans limited to fifty per cent of the appraised value made the purchase price, equipment, fertilizers,live stock,etc# buildings &nd improvements, discharge &f existing mortgages. of the land; (8 ) Applicant must state his intention to become within 3ix months engaged in the cultivation of the land mortgaged; (9 ) Loans to one borrower not to exceed $10,000, nor to be less than $200; 1 . (10) Application to be made in form approved by the Federal Farm Loan Board; (11) Borrower to pay ten per cent simple interest on de faulted payments; (12) The borrower must stipulate that if any portion of the loan is expended for purposes other than those speci fied in application, Or if he fails to comply with terms of application, the loan shall at the option of the mortgagee become due and payable. JOINT STOCK LAND BiMKS. Joint stock land banks possess substantially the same powers as Federal land banks. They may be organized by any number of natural persons not less than ten. They may begin business with a capitalization of $250,000 in states of less than two million inhabitants. The Government of the United States is not authorized to purchase or subscribe to any part of their capital stock. They are not subject to the restrictions above enumerated on logins made by Federal land banks, except that they are prohibited from receiving •« .41 655. - 7 - any commission or charge not authorized by the Act, directors may consist of more than five members. The board of The Federal Farm Loan Board has a more limited supervision over these banks than it has over Federal lalld banks. Bonds issued by these banks and known as joint stock land bank bonds are limited to fifteen times the amount of the capital and surplus. They are not subject to all the restrictions of farm loan bonds, but are based upon first mortgages and are in form prescribed by the Farm Loan Board. They are known as "joint stock bonds." MISCELLANEOUS PROVISIONS. The Act provides for examiners who are required to make regular examinations of the banks and associations and whose sal aries are paid out of the general funds of the United States Treas ury. It provides for appraisal committees to determine the value of the land offered as security and for a registrar to hold the securities against which farm loan bonds are issued. The usual penalties applicable to bank officers are incor porated in the Act. The provisions of Section 22 of the Federal Reserve Act are likewise incorporated. Farm loan bonds may be purchased by Federal reserve banks or member banks, by trustees or fiduciaries, and by the postal sav ings trustees. Acceptances or obligations of member banks secured by such bonds are madeeligible for discount by Federal Reserve banks. Ci M 655 These hanks and associations are required to carry twentyfive per cent of their earnings to a surplus or reserve account un til this account is equal to twenty per cent of their capital. Where national farm loan associations have not been organized in any lo cality after one year from the passage of the Act and it appears to the Federal Farm Loan Board that they are not likely to he or ganized, the Board may authorize Federal farm hanks to make loans through approved agentst One hundred thousand dollars is appropriated for organization expenses. Every Federal land hank and every national farm loan association, including the capital stock and reserve or surplus therein and the income derived therefrom, is exempt from Federal, State, municipal and local taxation, except taxes upon real estate held, purchased, or taken hy said hank or association under the provisions of Section eleven and Section thirteen of this Act. First mortgages executed to Federal land hanks, or to joint stock land hanks, and farm loan bonds issued under the provisions of this Act, are deemed and held to he instrumentalities of the Govern ment of the United States, and as such they and the income derived therefrom are exempt from Federal, State, municipal and local taxation. S I 655 - 9 - R E S U M E ’ The general plan of operation appears to be that, when farm owners or prospective farm owners desire to borrow money for the cultivation or improvement of farms or to pay off the purchase price of such land or to discharge existing liens, ten 6r more may unite to organize a farm loan association, subscribing and paying for capital stock in such association equal to five per cent of the loans desired. Through this association am application is made to the Federal land bank. This application must recite that the borrower is engaged or intends to engage in the cultivation of farm land< The Federal land bank may thereupon make loans to the farm lo a n a s s o c ia t io n on the s e c u r ity of f i r s t m ortgages to the extent of f i f t y per cent of the appraised Value of the in question. land All of such mortgages must run for a period of at le a s t fiv e years and not exceeding s ix t y yearsj and must Contain or annual an agreement for the payment of a fixed number of semi-annual/in*stallments sufficient to provide for am agreed rate of interest during the term and for the payment of the principal during and at the end of the term on the usual amortized plan. In order to increase their loanable funds Federal land banks may deposit first mortgages with a registrar as collateral security for bonds issued by such banks. These bonds which are engraved by the Bureau of Engraving and Printing under direction of the Comptroller of the Currency are issued in denominations of $25, $50, $100, $500, and $1,000. They have interest coupons at tached payable simi-annually and bear a rate of interest not to M Q2 -S j e o -LJl<JO - 10 - exceed five per dent. 655. The "bonds So prepared are deposited in the Treasury and sub-'-treasuries to be held subject to the order of the Federal Farm Loaii Board. When loans are repaid to the Federal land banks or to the joint stock land banks the proceeds are used (a) To pay off farm loan bonds as they mature, (b) To purchase such bonds, (c) To loan on first mortgages, (d) To purchase United States Government bonds, (e) To be held by t£e registrar as security for the payment of such bonds. » 5/15/16. 657 Remarks of Hon. Paul M. Warburg at the dinner of the Economic Club of New York, May 32nd, ISIS When, six reeks ago, I had the honor of ad dressing the Conference of the International High Commission at Buenos Aires, I told the delegates that I considered myself an "exchange professor" whose most important function, while in foreign countries, was not so much to teach as to learn and then, upon his return, to impart the useful in formation acquired t6 his own countrymen. This is the first opportunity which I have had to perform this mission, and I consider it, there fore, a duty to tell you one of the first and most inspiring impressions I received during my stay in foreign lands. This was at Rio de Janeiro, when our excellent Ambassador, the Honorable Edward Morgan, gave me the startling news that, in South America, after dinner speeches were not the fashion, and that Brazilians, in this respect as indeed in many others , were a highly advanced and kindly na 1165 657 (3) tion, permitting their guests to enjoy their dinner in peace'. From that moment on I began to enjoy my trip, and I mention this incident to you because I know it will be an added stimulus to many to start out for the v;onderful lands o f .our Southern Hemi sphere. I was much relieved to see from tonight's pro gram that I am not listed among the "speakers", but that I am classified only as a "guest of h o n o r " . Much as I should have enjoyed the privilege of ad dressing you at length, the accumulation of work since I returned two weeks ago has been such that, to my great regret, I had to inform your president, when accepting your kind invitation, that it would be quite impossible for me to prepare an address befitting this occasion. I am glad of this oppor tunity, however, to make a few informal remarks but not a speech. Permit me to say, then, how much I appreciate the great honor you have done me in inviting me to- 1186 657 » (3 ) night, how glad, I am to meet again my fellow members of this club, and with what pleasure I am looking forward to listening to the addresses to be deliv ered by your speakers. The topic, "New Opportunities for American Commerce and Industry" is, of course, one of the profoundest interest to me, particularly in its bearing upon our relations with our sister repub lics of South and Central America. In considering this question, we might well ask ourselves: are new for us? Why is it that these opportunities Is it that these countries have changed, that we have changed or .is it that the world about us has changed? The truth of the m a t ter is that most radical upheavals have taken place in all three directions, so drastic indeed that economic relations all over the ‘ w orld will have to be readjusted at the end of the war. The United States, in the beginning of 1914, was moving towards the position of an industrial 118? 657-4 and financial world power. The advent of the war precipitated this development with unparalleled rapidity and to an unprecedented degree; so that, as a result, our evolution from a mere agricultur al and borrowing community into a great agricu}industrial tural/and lending power has now been completed. While our own economic status has thus been strengthened, the wealthiest countries of Europe have been destroying their saving power at the rate of approximately $85,000,000 a day; and while our own economic position as against these other nations has been consolidated by a sure which has been estimated at about two to three billion dol lars, their own indebtedness has increased by more than thirty billions. And, unfortunately, this condition continues to grow and nobody can at this time foresee how long the cruel hand of destiny will continue to grind into dust what it has taken generations of human toil and endeavor to create. 1 1 8 8 65?-5 When we look into the future we ponder and wonder hovj these countries will manage to carry the burden under which they have to struggle. While we still hope that the load will not smother them, there is no doubt but that it will absorb so much of their strength that other countries that in the past have been developed largely by the excess saving power of some of these nations will, for years to come, fin d ,this fountaih fun dry or at least drastically reduced. That means, generally speaking, that the economic progress of our globe 'will be retarded for a generation or more, and that those nations will feel it the most that were accustomed to depend upon European funds for the development of their resources and had not proceeded far enough in this development to be able, as we were, to dispense with the assistance afforded by foreign capital. This thought was borne in on me very vividly in South America. Magnificent countries, resplend- 1189 S57-S ent with natural wealth and wonderful opportuni ties are now threatened in their progress by a struggle not their own and thousands of miles away. The deep significance of the situation impressed me all the more because of its similarity to the history and the problems of our own country and because .1 was conscious of the fact that the Unit ed States would have been in precisely the same position had this world conflagration taken place some twenty years earlier. We have to visit these great South American republics in order to realize the strong bond of affinity that exists between them and ourselves; in spite of differences in antecedents and language. When I spent an afternoon at the country house of a leading cabinet minister of one of these re publics - a house possessed by the family for gen erations - when I admired the wonderful old trees , the rooms full of books and art treasures, the ■walls covered with beautiful pictures of all 1170 657-7 schools , when I glanced at the old family portraits - and the new ones by Zorn, Sargent and Boldini - I had the same feeling that an old Hew England or Pennsylvania or Virginia family mansion 'will awaken in u s , or an old house in Washington Square in New York. Here, indeed, I saw the descendants of- the Spanish Pilgrim Fathers'. And again, when I studied the histories of these nations and saw their monu ments erected to the memory of Bolivar and San Ma r tin, I fully realized that these countries, too, had their Washingtons and their glorious wars of independence and their periods of transformation from colonial dependencies into sovereign republics. They have their race problems, their, immigration problems ana, like the United States, while reaping the advantages of a democratic form of government, they too have to struggle with the difficulties caused oy the premature and indiscriminate granting of equal suffrage to masses at the time not sufficiently educat ed. But, gentlemen, visit Uruguay, the republic 1171. * 657-8 that, ten years ago, held the record for frequent revolutions, and you will now find that it is the Stats of Wisconsin of South America, or - perhaps it out-Wisconsins Wisconsin, You find a most mod ern, highly progressive administration; governmentowned banks, and lighting plants, trams and hotels owned by the municipality; beautiful universities, splendid agricultural and veterinary schools,' and prisons so attractive and modern that I asked to have a cell reserved for myself - in case of need. And as the keen and intelligent men, now in charge of the administration of the country take you through their public buildings, and as you see the wealth and progress of.the country, there comes to you the profound conviction that the swamps breed ing the mosquito that spreads the infection of that are the foumd-tion of our own national growth: the influences revolution are laid dry by the same influences/of education, industry and political equality and liberty. I wish that etiquette would permit ms to de- 1172 657-9 scribe to you some of the statesmen we met. I use the word statesman advisedly, for w e found men of the rarest type, courageous and sincere and inspir ed by the highest ideals. It would be presumptuous on my part - after so rapid a visit to these vast countries - to at tempt to picture to you the indescribable charm of Rio, or the untold and untouched riches of Brazil a country larger by 269,000 square miles than the United States proper and having a population of only about twenty-three million people - or the endless Argentine plans, teeming with grazing cat tle, or Buenos Aires, the city of over a million and a half inhabitants, with New York spirit and Paris taste, or Chile, the California of South Am erica, with its wonderful climate, its virile race, its undeveloped water powers and mineral wealth. I can venture only to speak to you in bird'seye-view terms. But, speaking in these terms and fully conscious of the fact that generalization can ±73 * 657-10 never do justice to all the phases it appears to cover, we might say that the wealth of these coun tries, the lavishness with which nature has treat ed them,, h a s , to a certain extent, been the cause of their weakness. It has made many of them de pendent upon the marketing of a few single staplesbe they coffee, rubber, cattle, wheat, nitrates or guano - it has prevented them from diversifying their industries, from producing at home many a thing that they purchase abroad, and it has made them extravagant instead of teaching them thrift. And again, gentlemen, we need not go very far to find the parallel in our own country. The present world crisis has taught them - as it has taught us - the necessity of economizing, of importing less extravagantly, and of developing more intensively their own resources and industries. At the same time, it has brought home to them most forcibly the other necessity of never again being found dependent exclusively upon the ships, credit '•$ "I 74 657-11 or good, will of Europe to reach their markets. It is not only a humiliation to the national pride of these nations to be told from whom they may buy in their own countries and to whom they may sell abroad, but their very economic life has been placed in jeopardy by the temporary withdrawal of shipping and banking facilities, and by the extortionate freight rates exacted for what little tonnage has still been left over to take care of their trade. They look to us to remedy a situation which is as unbearable to them as it is to ourselves. They feel themselves at one with us in this respect, for it is for our own protection as well as theirs that the "stars and stripes" must fly over a mer cantile fleet large enough to ensure the independ ence of the trade of this hemisphere! They fur thermore trust that our own financial emancipation will be an important factor in securing greater financial independence to them. I returned from these Southern shores with the feeling that North, Central and South America are one economic unit, not only because nature has made us neighbors, inhabitants of the same great conti nent, but because our historic traditions, our po litical ideals and our economic problems and inter ests are substantially the same. While they are following in our wake, we are headed for the same goal, and the rocks and cliffs are the same in their course as in ours. Central and South America and the United States are not competitors; they supplement one another. The more our population grows; the more we develop into an industrial nation, the more we ourselves shall consume foodstuffs that we used to export in the past, the more shall we be called upon to im port the products of the Southern Hemisphere and export in return the articles that our manufactur ers will supply. It is but a short time since we began to take 1176 657-13 an interest in South and Central American affairs. The reason is clear; economically ce had not reached the point of development of being an industrial and, from the banking point of view, a lending nation. The consequence was that we were provincial, satis fied 'with our business opportunities at home, and unwilling to study and adjust ourselves to the habits and thoughts of other nations. Changed conditions have brought about a dif ferent condition of mind. sides. A change of mind on both As Ambassador Stimson put it in a speech at Buenos Aires, we were like fishermen living in a d joining cottages facing the Atlantic, having all the windows towards the ocean, and looking across the sea'all the time, with no means to look at each other. We now have broken a window into the ad joining wall; for the first time we begin to know and understand each other, and I, for one, should like to prophesy that, by mutual consent, very soon we shall widen that window rapidly and make it a 657-14 very large and. comfortable door. How that may best be done, others better qualified than I will discuss tonight. Let me express only these general thoughts: Europe's saving power being crippled while our finan cial power has grown by her misfortune, there is no doubt that it will be both our opportunity and our duty to assist in developing the resources and indus tries of those of our sister republics that are still dependent upon foreign credit for the completion of their economic development. Let us bear in mind, however, that the best business policy is not only the square deal, but the fair deal, permanent business relations are not established by driving a hard bargain, but by trans actions fair and equitable to both parties, and that applies as much to the South and Central American who desires to establish a market for his goods or securities with us as it does to the North American entering these new fields. 78 657-15 Furthermore, in order to perfect the establish ment of intimate relatiorts with these nations, we must understand and speak their languages-. dence is the basis of business. X Confi If we do net under- stand these people, their methods or their point of view, we cannot deal with them with that considera tion and discrimination to which every human race is entitled. We must be able to discriminate be tween the good and the bad amongst them, as they must be able to discriminate between us, but, having found the best, we must deal with them on the basis of the same full confidence and equality as we would deal with the very best amongst ourselves. I wish that I could impress our business men with the importance of sending abroad only men of experience and high standing, such as enjoy their confidence to a sufficient degree to permit them to discriminate and not be bound by uniform and narrowrestrictions. Let us remember that a country is often judged by the first business representatives ■f±79 657-16 it sends abroad, and let us, therefore, do all we can to keep away all elements that might do injury to the standing and reputation of our merchants and manufacturers. The United States Chamber of Commerce agreements for the arbitration of busi ness disputes will be important factors in pro tecting the good name of American business men in foreign lands. vail. Glib talk and speeches will not a- We shall be judged by our acts. And, furthermore, while, for years to come, we shall have a telling advantage in all work of devel opment leading to more or less permanent investment in South and Central America, Europe will bend every effort at the end of the war to regain her full share in the regular commerce of these countries. She will need this trade much more than we do and we shall not be able to secure a fair proportion except by a determined and persistent effort. These markets cannot be conquered by spasmodic outbursts of energy and enthusiasm, but only by unrelenting "ISO I 657-17 ana well organised work. Nor can re expect to succeed unless this, our "land Of lioerty", gives as much freedom to American enterprise - merchant, manufacturer, shipper or banker - as is enjoyed by our European competitors. Our banks must be as free to go into foreign coun tries and to finance this foreign trade according to the local usages and requirements as are the Eu ropean banks, which are practically free from legis lative restrictions in this respect. Great headway has already been made during these last two years, and we have reasons to hope that some of the recom mendations made by the Federal Reserve Board tend ing further to increase the scope and efficiency of American banking in foreign countries will be acted upon promptly and favorably by Congress. A discussion of "New Opportunities for Ameri can Commerce and Industry" naturally brings to mind two of the most constructive achievements of our generation — the Federal Reserve Act and the Panama I 657-13 Canal. It is impossible, however, to discuss to night the important effect of the Federal Reserve System upon the development of our foreign trade and the great progress already made by our banks in these fields, or to describe the thrilling impres sions received by us all during our trip through the Panama Canal, this wonderful piece of engineer ing which, by cutting apart the North and the South, brought them so much closer together. Let me, in closing, relate to you only one little incident that deeply impressed me at Panama. Admiral's wife said to me: An American "I am sorry we have to leave Panama and go home, because it is such a splendid place for my children."! Panama and yellow fever 7«Tere words almost synonymous in the past; no higher compliment 'was ever paid American engineering and medical skill than this mother's comment. It is this kind of viork - the beginning of which we saw at Haiti and the complete, final success of which we perceived at Habana - that constitutes the I 657-19 highest type of constructive work, a contribution upon which every American may look with just pride* I hope that American business will make for itself an equally good record. Our South and Cen tral American fellow citizens 'will then esteem and love us - even though we should carry into their innocent countries the bad habit of after-dinner speeches. Finis. 5- 18- 1 6 . 1183 658 RELEASE FOR PUBLICATION IN AFTERNOON PAPERS MAY 2 ^ iqi6 NOT EARLIER. HOW THE FEDERAL RESERVE SYSTEM IS MEETINO THE REQUIREMENTS Address of A. C. MILLER Member of the Federal Reserve Board Delivered May 2k, igi6 at the Annual Convention of the MISSOURI BANKERS’ ASSOCIATION at St. Louis RELEASED FOR PUBLICATION IN AFTERNOON PAPERS OF MAY 2*1,1916. ^ HOW THE FEDERAL RESERVE SYSTEM IS. MEETING THE REQUIREMENTS. * * * * * The financial outlook for the United States has never been so full of interesting possibilities as at the present time, nor has it ever called for a more definite understanding of whence we have come, where we are at, and whither we are going. In the course of the past year and a half we have replaced financial dependence upon Europe by dependence upon ourselves and we have also been able to extend a very considerable measure of financial service to some of the warring nations, and to many of the neutral countries of South America. The record of our material and fi nancial progress in the past year and a half discloses results which are stupendous and seem little short of miraculous. Much has been said of our new opportunities; but it is important that the banker, who has a very serious part in shaping the course of business and tempering the spirit of the community to a new situation, should recognize that the situa tion with which we are confronted is not alone pregnant with op portunity, but is also weighted with serious responsibility. It is, indeed, doubtfullwhether any country in the history of modern commerce has ever been faced by a situation so calculated 658 -2- to challenge the best of which it is capable in conceiving and carrying to fulfillment great plans. It is a situation which invites to a mastery in the world of finance and of large affairs; but to attain this mastery we must first be come masters of ourselves and of our own by developing to highest efficiency instruments of direction and control which match our splendid resources. It calls, moreover, for a new type of business leadership and a capacity for co ordinated action on a larger scale than we have been accus tomed to in order that we may be able to act with wisdom, vigor and effect in this new region of affairs and responsi bilities into which we have entered. It is fortunate,- indeed it would be difficult to exaggerate the degree of our good fortune,— that the most im portant and considerable step toward fitting ourselves to meet the new occasion should have been taken in advance of the great changes in the sphere of international relationships, which are bound to come as one of the results of the war. I refer of course to the establishment of our new banking organization, the Federal Reserve System. That system, and what it stands for, must be, as indeed, it has already proved itself to be, our chief reliance in meeting our new responsibilities and in turn ing our new opportunities to profitable account for ourselves 1186 and to benefit for the rest of the world. No agency of resource in the field of finance which the nation today possesses or has ever possessed is comparable in its potentialities to the Fed eral Reserve System* It is, not only the newest thing in Amer ican finance, but also the best thing. Until we definitely understand this, we are not in a position to do our best in meeting the new occasion. To recognize this is the beginning of wisdom. It is also well that we should recognize that the atmosphere was never so propitious for the discussion of ques tions of finance upon the broad and high jslane of national interest and policy as now. I believe I speak truly and with strict fidelity to the historical record, when I say that for the first time since we, as a nation, began to make financial history, questions of currency and finance and banking have ceased to be political and party questions. To have taken the banking question out of politics, where it long fingered to the prejudice of the nation’s commercial and financial interest, is a matter of sufficient moment and promise to en title it to rank as a real achievement. Whatever differences may have existed on questions of banking policy before the establishment of the federal Beserve System/ they have pretty much ceased to exist since. The country, as ybu know, has set its approval upon the federal Reserve Act as a piece ol funda mental legislation on which to build arid Uhdef which we are to develop the banking system of our expanding industry and commerce for delcadsS to come. So well was the work of legis lation done, and Sc completely hafe the result been accepted and approved by the business; b&rikihg and general public opin ion, that the banking question has fortunately at Iasi ceased to be a problem of legislation and has become one cl admihis* tration. Congress has given us a superb instrumentality; it is for our bankers and those who are charged with the adminis tration of the new law strumentality to do their part in using this new in wisely and effectively in strengthening the financial foundations of our industry and promoting its healthy, prosperous and steady growth. . The test of a banking system is the aid it gives to productive enterprise by supplying its credit needs. Banks become powerful and valuable auxiliaries in the industrial system in proportion as they give increased activity and mobility to the community’s industrial and commercial capital; 658 -5and 'banking profits and prosperity are never so legitimate and so fair an indication of the character and quality of the service banks are rendering, as when they prosper and flourish along with the communities in which they exist. The changes which were made in our banking system under the Federal Re" serve Act were designed to accomplish many different things, but the goal toward which everything pointed was that of mak ing the nation*s credit facilities more widely available in all useful and legitimate ways for industrial and commer cial employment on terms of safety, and of such ease as is consistent with safety. How far the new banking system is fulfilling the promise of its sponsors and meeting the expec tations of .the nation, more particularly how it has met the a tests which its first year and/half have brought, are ques tions of the kind which suggest themselves at a time when the nation, throughout its length and breadth, is taking stock of its capabilities and when "preparedness" is its watchword. For the new system is no longer a theory, but a fact. It is in actual operation, with a record which can be examined, and which can be tested by results. 658 •f The new "banking organization has already found its place in the American financial system and has already made an enviable history for itself. Its influence has not only been felt in every part of the country, but has reached across the seas. It has had to meet conditions and circumstances in many respects more unusual than could have been contemplated by its framers, and yet so well contrived and so flexible is the structure of the new banking sys tem that it has been found capable of adjusting itself to each new condition. It has thereby given evidence of its capacity for growth and development along with the changing and expanding needs of the American credit and business system. It is just this qual ity which takes the Federal Reserve Act out of the class of ordi nary financial legislation and makes the new banking organization a system in a very real and far-reaching sense. In breadth of conception the Reserve Act is a constitution rather than a statute; a financial constitution characterised, as an organic act should be, by that quality of adaptiveness which has always been the boast of our great ■political constitution, and a quality which v<e have long since come to regard as an essential, not to say the sovereign, element in any great and vital piece of constructive legislation. In reviewing the working of the Federal Reserve Banks I wish to direct your attention to four or five aspects of the new 658 - 7- system which in my judgment are calculated to disclose the capab ilities of the system and the temper and wisdom of its adminis tration. 1. It has facilitated the growth and financing of the country's enormous foreign trade. 2. It has met the requirements, of domestic trade, par ticularly the requirements of the crop-moving season and has shown a capacity to ease and steady discount rates. 3* It has shown capacity to absorb the redundant gold of the country and restrain inflation. It has shown capacity to maintain an atmosphere of confidence.1 1. Growth and financing of foreign trade. The‘financing of our foreign trade was always a sensi tive point in our credit system, and foreign exchange has long been regarded as a very accurate barometer of our international position. The year 1915 witnessed the largest foreign trade ever experienced by this country, the export trade particularly attaining the colos sal magnitude of $3 ,600,000 ,000, an amount $1 ,000,000,000 of the highest amount hitherto recorded. in excess 658 -8- The large excesd of exports Over imports of merchandise credted a balance of trade ift our favor of unprecedented character and dimersitms and subjected our purchasers to the necessity of resorting to the American money market in order to obtain funds with which to meet their obligations. The new banking system met every requirement of this -unprecedented situation without diffi culty. At no time since the opening of the Reserve banks has there ever been any doubt of the ability of our banking system, by means of the newly established system of acceptance credits or otherwise, to take care of the financing of the country's ex ports, however large the excess of these over imports might become. The growth in our exports has been continuous,. The last month for vdiich w9 have complete figures, March, 1916, 3hows exports over $100,000,00s) in excess of March,, 1915.> an aggregate of $U09,850,~ and which promises an estimated total for the year of be tween $U,000,000,000 and $5 ,000,000,000 . When we contrast the ease with, vsiiich we now finance a volume of trade which would have staggered the imagination a few years ago, with the clumsy shifts to vdiich we were frequently reduced under our old methods of fi nancing, we get some idea of how fundamentally and effectively our banking machinery has been improved by substituting for a precar ious dependence upon foreign facilities those of our own making 653 and control. You bankers will recall the situation into which our foreign exchange was plunged at the beginning of the European war before our new banking machinery had "been set in operation. Our bankers, as had long been their custom, had drawn heavily during the summer on England. The estimated amount of our short time indebtedness maturing before the first of January, 1915; was from four to five hundred millions of dollars. expected that It had been this would be taken Care Of by the proceeds of cotton and grain bills which would, be drawn with the export of crops. The sudden suspension of our foreign trade and equally sudden termination of our foreign banking credits left us in a serious position. I recall a conference of momentous import, held in the office of the Federal Reserve Board and attended by leading bankers identified with international financing, at which was discussed whether and how our accruing obligations could be met. It was decided that they could be met and there fore should be met no matter at what inconvenience to ourselves and no matter at what cost in the loss of gold. 3y that act \ was laid a foundation for the future of .America as a world banker and to the faith thus inspired in the integrity and the capacity of the .American banking system we owe very largely the 658 -10enviable position that. we have, in the brief period of little sore than a year, attained in the international money market. Such an embarrassment as we suffered in the early autumn of 191U is all but unthinkable under our new banking system, unless there should be a breakdown of transportation facilities. is not a theory; This it is a fact which is thoroughly attested by the experience and events of the past year- We have not only received from Europe during the year ISiy over $’ 4-00,000,000 in gold, but we have taken back American securities and arranged additional credits to a combined total estimated at $2,000,000,- 000. A year ago dollar credits were practically unknown in a foreign centers; today dollar exchange is,/re cognized and estab lished medium of international commerce and one of the most prized, because the most stable, unit of international payment. The acceptance business, iGr many generations the peculiar do main of English banks and the source of much of England’s pres tige and power and profit in banking, has been successfully natur alized on American soil and is thriving. Complete and accurate figures are not available, but it is a safe statement that the volume of acceptance credits created in behalf of the foreign trade of this country has averaged for several months $100,000,000 and 658 -n~ now amounts to over $200, OCC,OCO, nnd the amount heid by th& Rsv" serve 'banks to $U8,000,000. The certain knowledge that accept ances of a sound character will find ready discount 6 t purchase at the counters of the Federal reserve banks and at rates as low as two per cent, which is lower than has ever been enjoyed by any class of commercial paper in this country, has given a feeling of assurance to our bankers in entering this new and un familiar field and has thus enabled them to gain a foothold in it and to make it for all time an important and invaluable de partment of American banking. 2. Domestic trade, crop-moving, and discount policy. While this important extension of American banking en terprise into the foreign field was taking place, our banking sys tem, with the support of the Federal Reserve Banks, was assisting in the tecuperation and extension of our home trade and industry. The home‘trade i3, after all, the basis of the country’s indus trial activity and prosperity. However large and important the foreign trade may bulk in the popular imagination, however muchattention may be given to it in the financial columns, and how ever important it may be in fact, it is still the truth, which 1195 deserves to Toe emphasized, that ours is primarily a country of inland trade and industry, Among the nations which have reached a high degree of economic development, there is no other in which inland trade beass so large a proportion to foreign trade. Ac cording to competent estimates, it is at least twenty-fold the volume of our foreign trade and it is therefore the necessities and the interests of our home production and consumption that deserve especial consideration in any attempt to estimate how well it is being served by the banking organization. Are its needs being supplied on reasonable terms and with the assurance that accommodation can always be had on s atisfactory security? To ask this question is to answer it, so universal is the knowl edge of the comfortable conditions which have obtained in the money markets of the country and generally throughout the coun try since the Reserve banks were put into operation. How completely the requirements of the crop-moving season have been met is also a matter of wide experience, if not of common knowledge. Never before within the recollection of this generation have the credit and currency needs incident to the gathering and the movement of the crops been met so easily and so smoothly and so quietly. The operation of the Gold Set tlement Fund which has been established to facilitate the settle 1196 658 -1 3 - ment of exchange3 among the Reserve "banks and to reduce to the lowest point the shipment of currency from one part of the covintry to another, ie, in large measure to be. credited with the happy result which has been attained. The autumnal pressure on leading money markets and the consequent tightening of money rates has come to he regarded by many as something that was in evitable in a country subject to such large periodic require ments of cash for the movement of its staple crops. The last crop-moving season, the first which ha3 had the benefit of the machinery of the Federal Reserve banking system, passed without any untoward incident and without any indication of perturbation or strain in the great money centers. Indeed, if the. experience of the past j’ear may be taken, as I believe it may, as prophetic of the great change wrought in our banking'mechanism by the Fed eral Reserve Act, the disturbances associated in the: past with the autumn requirements may be regarded as an easily manageable factor in cur credit ahd banking situation. This, in itself, is a tri umph which deserves to be signalized in estimating the workings of our new banking system. With rates ruling as high a 3 six per cent .for commer cial paper when the Federal Reserve Banks were opened in the late autumn of 19 lH, and when the financial disorders .incident to the 1197 658 -lU- European war still presented a troublesome situation, and with some variation of rates between different districts, the Reserve banks, during the year 1915 / greatly reduced the general level of discount rates and maintained them at a remarkably steady level. The opening quarter of the year 1916 saw rates of from two to four per cent on bankers1 acceptances, the rate in actual practice, however, running very close to the lower limit. Trade acceptances at rates of from thi'ee to three-and-a-half per cent; rates on short-term paper up to ninety days at rates of from four to four-and-a-half per cent, were the noteworthy features in the discount rate situation. The fact that rates a3 low as three and three-and-a-half per cent were established on commodity paper,(that is, notes and bills secured by x'eadily marketable staples), and the further fact that the Reserve banks stood ready to take and have freely taken agricultural paper at rates of four-and-a-half to six per cent, shows that the banking accommodation provided by the new system is not restricted to any class of borrowers but is available to all classes where the security is of the type ap proved for Reserve bank operations. .These various rates are lower than have ever been en joyed for like classes of paper in any considerable section of the country. What i3 perhaps more important from the point of 658 - 15- view of the geographical distribution of the facilities of the new system, there has "been a marked approach to uniformity of rates among the several Reserve banking districts, a nearer ap proach than has heretofore been experienced. Whether it will be practicable for a long time to come to maintain identical rates throughout the twelve Federal reserve districts has been questioned. Such an outcome may not be likely as long as there are marked differences in point of economic maturity in the different sections of the country, nor is the successful opera tion of the Federal reserve system predicated upon the assump tion that discount rates must be uniform in all the reserve districts. lOne of the important features in which the region al system differs from the plan of the National Monetary Commis sion for a central bank with branches is that it does not re quire uniformity of discount rates but allows these rates to be adjusted to the conditions of demand and supply in the respect ive districts. These conditions are admittedly so divergent that any attempt to ignore them altogether in the determina tion of Reserve bank rates might well be regarded as undue in terference with the necessary operation of natural forces and would sooner or later result in embarrassment. As long as the different sections of this vast country of ours are in differ- ent stages of economic development with respect to the need for, and the accumulation of, capital, it i3 to be expected that there will be differences in the rate of interest and also , therefore, of discount rates. But the disparity which long ob tained between the rates in some of the younger and less highly developed sections and the older centers, was undoubtedly in large measure due to the peculiar banking policies and prac tices which had grown up under our old banking system, and which were, to a certain extent, fostered by the law. But whatever the causes, the result- was an artificial disturbance of the natural distribution of the country's supply of credit facili ties and a condition which threatened, if left to itself, to develop into an artificial and unwholesome interference with the free flow of the nation13 credits. To the extent that such was the case, differences of commercial rates were without solid justification in economic law and to that extent at least we may expect that these differences will be mitigated, if not altogether eliminated, under the operation of the forces sot in action by the Reserve Act for diffusion of credit facili ties and for local control of credit conditions by regional banks. The rates which have been maintained by the Reserve 1200 -i7- 658 Banks throughout the past year or more are probably not to' be regarded as normal, except in a temporary sense. The conditions ol the past year and a half have admittedly been extraordinary and have worked toward easy conditions in the credit markets of the country. When we have digested the immense volume of poten tial credit set free by the new banking reform and are no longer subject to the depressing influence on rates exercised by the great influx of gold which we have had, it is certain that rates will advance. How soon the demand will catch up with the supply can only be conjectured; so too, it is a matter of conjecture what the normal rate of discount will be when the demand and supply of loanable funds are more nearly in equilibrium. Much will depend upon what is one of the most difficult of the war’s effects to forecast; namely, the effect of the interruption and suspension of a large part of the customary commerce and in dustry of the European world and the destruction of an untold amount of industrial capital, upon the permanent interest rate. In the long run the interest rate on fixed investments is bound to influence short term money rates. In the long run, too, there will be a tendency for both investment rates and commercial rates in the leading financial centers of the world to move toward a common level. The course of the money market 658 -18 in this country is, therefore,* hound, to be in very considerable degree influenced by the course of the leading money markets of Europe. Speaking for myself, let me say that I cm under no illu sion with respect to the function of the Reserve Banks in our credit system, nor any with respect to the Federal Reserve Board's position and power as the ultimate authority in the determination of discount rates. The Federal Reserve Act has invested the Board with extensive powers, in the fixing of discount rates but it has also charged the Board with the responsibility of seeing to it that rates are sc fixed as " to accommodate commerce and business", thus indicating that the fixing of discount rates is an exercise of economic and business judgment, not an arbitrary choice. No body of men in my opinion would be competent to shape the policies or guide the destinies of our new banking system, who did not realize that the determination of discount rates at their proper levels was more a matter of the wise application of economic law than of hasty or careless experimentation with statute law; a question of the conditions affecting the demand and supply of, loanable funds, present and prospective, as re flected in the market for short term commercial loans. The Re serve Banks will, therefore, show wisdom in recommending, and the -1 9 - 658 Federal Reserve Board will show wisdom in sanctioning only such rates as correctly interpret the trend of business and credit conditions and needs, so as, in a genuine sense, " to accommo date commerce and business". For the Federal Reserve System is not above or beyond economic law. There is a magic in the Federal Reserve System but it is no venture in financial alchemy. It cannot make something out of nothing, nor for any length of time, and except at the cost of serious injury to,the movement of the country’s industry, maintain rates that are out of line with the natural economic trend. It would be poor policy, at any time, to favor present business at the expense of calculable future needs or require ments, nor should accommodation be withheld from present busi ness because of undue solicitude or fear for possible future requirements. Such rates would not "accommodate". In the one case they would be too low, in the other too high; but the error committed and its mischievous effects would usually not become manifest until the results were well beyond control. The Federal Reserve Banks as a whole might have maintained rates at a very much lower .level than has been in effect during the past year or more, but it is hard for me ■1203 •20- 658 to see what good purpose would have "been served by such abnormally low rates. As I view it, the chief results would have probably been, first, to have given an unhealthful stimulation to business enterprise of doubtful validity, possibly going sc far as to work a dangerous inflation of credit and the launching of undertakings that would later on have been caught an the grip of rising rates; end, second, to have narrowed the margin of banking profit, more especially in sections of the country which are for the first time experiencing the levelling influence on rates of a fluid credit system. I need hardly point out that lower rates would have borne hard on those of you who still follow the costly practice of paying inordinately high rates of interest on depositors' accounts. It is a familiar fact that in many parts of the country, banking competition, has raised the rats of interest paid on savings accounts to a point where industrial development is retarded and bankers' profits threatened. It is well to encourage thrift by suitable inducements, out the matter is overdone when the induce ment in the shape of interest goes beyond the rate war- 658 —21- ranted by industrial conditions, and thereby diminishes the incentive to individual investment and enterprise. And this leads me to remark in passing that I believe that there must be a readjustment in the interest paid to depositors to con form to the reductions in the rates of interest and discount which will result under the moderating influence of the new banking conditions. 3. Absorption of redundant gold and checking of Inflationary tendencies. I am afraid that the great influence exerted by the Federal Reserve Banks in steadying the movement and level of rates is not generally appreciated at its full value and significance. The wise policy of conservatism and self- restraint which has been pursued by the Reserve Banks as a whole has given to the movement of industrial expansion which has been under way for the past year, taking the country by and large, a quality of health and solidity that it would almost certainly not otherwise have possessed. In this, the first substantial trial of the Federal Reserve System's capacity for leadership, its success has been un questionable. It has, ®o far as its situation permitted, created an atmosphere conducive to healthy expansion, and % 658 -22- has used such influences as it could command to temper the spirit of reckless adventure and prevent it from becoming a menace to the country's welfare. The result has been that the forward movement in industry which every part of the coun try has been experiencing in greater or less degree, has been one of the most substantial that the country has ever known. How easily it might have been otherwise can be conjectured by those who have not forgotten how often incipient indus trial prosperity has been turned into misadventure and col lapse in the olden days, because of the lack of the guid ing and steadying influence of such authoritative and com petent leadership as the country now enjoys. You will recall how frequently and confidently, up to the very last moment preceding the passage of the Federal Reserve Act, the prophecy was made that the new banking system about would bring./inflation, especially inflation of currency. One of the primary purposes of the Federal Reserve Act was to provide a method of elastic note issue. It is, of course, obvious that there can be no elasticity of circulation with out the possibility of expansion which may, if the manage ment of note issues is in incompetent hands, lead to inflation. r\ w ‘U 658 -23- Discretion mu3t lodge somowhore, :.nd if it bo abu3ed,bad donssquences will result* How carefully the new system has func tioned in this respect,* and how prudently it has used its issuing power to diminish, rather than aggravate any tend ency toward inflation of credit is one of the most grati fying evidences of the wisdom of our new banking law and the ability of its managers. This deserves to be made clear* for there has been much misconception of the policy which has been pursued by the banks with respect to note issues. The statement is sometimes made by persons who have not taken the trouble to inform themselves, that there has been a great expansion of the Federal reserve note cir culation at a time and voider conditions when there was no need of additional currency. What are the facts ? If you look at the Daily Statement of the Treasury for May 13, 1916, you will find that $187,166,000 of Federal reserve notes have been issued by the Federal Reserve Agents or the Grovernment to the Federal Reserve Banks. The Federal reserve notes are of course obligations of the Government as well as of the issuing banks and are issued by the Govern ment to the banks and by them to the public. Before we can determine what, if any, influence has been exerted by the Federal reserve notes issued by the 8 Government in augmenting the money supply of the country, we need, of course, to know on what basis the banks have issued the notes to the public, and also what portion of the notes that have been issued by the Government to the banks are held in the bank's vaults. On may 13, 1916, it appears that $37,218,000 of Federal reserve notes issued to the banks had not yet been issued to the public, and of the $159,948,000 outstanding and issued to the public, all but $9,567,000 had been issued in exchange for gold. That is to say, that except for $9,567,000 of Federal reserve notes outstanding against which the Government holds commercial paper for an equal amount and the banks hold a gold reserve of 40$, there was for every dollar of Federal reserve notes issued to the public by the Reserve Banks a dollar of gold taken from the public by the banks and deposited with the Federal Reserve Agents, representing the Government. In brief, to this extent the Federal reserve note is tantamount to a gold certificate or warehouse receipt for gold. " ',2 0 8 - 25 - A dollar of reserve money is, by usual computation, estimated to "be capable of supporting a volume of credit in the customary form of deposit liabilities, of four or five times itself. When, therefore, it is recalled that the Federal re serve note is not legal tender and cannot therefore he counted in the reserves of the national hanks, you can readily see how the policy and method which the Federal Reserve Banks have pur sued in the management of. their Federal reserve issues, so far from inflating the bankable funds of the country, has actually reduced them by a large amount. In other words, of the vast amount of $4-19/356/000 hi gold which the country received in settlement of the international balance during the year 1915 / and which, if allowed to accumulate in the reserves of the banks would have threatened a serious unsettlement and disturbance in our credit situation, 36 $ (or $150,381,000) has been drained off and stored up in the keeping of the Federal Reserve Agents until such time as changed conditions and the interests of com merce and industry may require its use. The note-issuing policy pursued by the banks has thus had the twofold effect of actually diminishing the tendency to inflation through substituting the note in place of gold and, at the same time, has provided a defi nite reservoir of gold which can be tapped without producing any shock or anxiety when the inevitable demand begins for the re turn to Europe of some considerable part., if not the whole, of the gold whicfc necessity has obliged Europe to part with to us. So far from being a source or cause of inflation, the very oppo site is the case, and the country owes much to the salutary action of the Federal reserve issues in mitigating the effects of the gold influx. ■Whether vie could or how we would have dealt with the problem of the increasing gold supply had we not fortunately had the agency of the Federal Reserve Banks, may well be questioned; but it is worthy of remark and careful consideration that although a condition so extraordinary as thi3 was probably never contem plated by the framers of the Federal Reserve Act, and therefore no special provision made for it, nevertheless, so well conceived was the general framework and machinery of the system that it was « found that it could be turned to useful account in meeting the situation created by the presence of the redundant gold supplies. 4. Commercial confidence. I have reviewed, perhaps at what has seemed to you tedious length, three distinct, important and difficult kinds of service which the Federal reserve organization has rendered in 658 - 27 - the first year and a half of its existence - a period character ized in its general aspects by much uncertainty and anxiety - in order to show how the new hanking system is standing the test. It has met every requirement in the financing of the largest export trade the country has ever enjoyed; it has equalized and steadied discount rates at a low level throughout every district of the country and in this connection it has withstood the temptation to utilize its vast resources and power to depress discount rates to the point where both a dissipation of its resources and an unhealthful stimulus would result; and,, thirdly, it has done much to check the inflationary tendency threatened by the huge influx of gold. I come now to a fourth matter which is in some respects equal in importance to any of the others, if not of greater import ance, because it has underlain each one of them guid has made pos sible the definite and signal results which have been achieved. I refer to the atmosphere of confidence that has been induced and maintained from the very day and even before the day of the open ing of the Federal Reserve Banks, and in every section of the coun try. It is, of course, hard, not to say impossible, to estimate the value of any element of business health and activity so intan gible as confidence, and yet it is of the very essence and life of the modern business system. Business is largely a state of mind. Business flourishes in the atmosphere of hope and the sun shine of cheer; it is chilled and choked by the poisonous vapors of fear and anxiety and is paralysed by the atmos phere of despair. The method of the Federal Reserve Sys tem,, I trust you understand by this time, is the method of hope and of encouragement. It is this quality which dis tinguishes the Federal reserve legislation from any other im portant piece of legislation ever enacted by our Government touching the fortunes of business. It is this quality which entitles it to be regarded in a very genuine and critical sense as a product of constructive statesmanship. It is this quality which makes the advent of the Federal Reserve System mark an epoch in the business life of America a.nd a atep of incalculable length in the development of the new relations which the statesmanship of the future will seek to cultivate between the agencies of Government and the agencies of business. That it has thus far succeeded in this vital function, the past year and a half bears eloquent testi mony. A more striking contrast of conditions than those which confronted the country at the inception of the Federal Reserve System, when business and financial chaos was im- ,* r$4i O i'J pending as a result of the outbreak of the European war, and those which have obtained since the banks were set in operation, can not be found. Our international relations during the year 1315 -were narked by several critical episodes any one of which under ordinary conditions would have thrown business into convulsion.' Public opinion and feeling has on several occasions been in a state of extreme tension- VThen we recall the Lusitania incident, the Arabic, Ancona> and Sus sex, to say nothing of the Mexican tangle, we can readily under stand why war at times seemea to many imminent, and to some a certainty, and yet throughout it all the business pulse has been strong and steady and firm. There has been little of a dramatic or sensational character to .record in our recent business annals. There have been moments when that sen sitive barometer of business feeling, the stock market, ha3 registered some nervousness and hesitation, but nothing for a moment comparable with the disturbance and shock following threatened ruptures in our foreign relations bn former oc casions, so unqualified has been the confidence that the business community as a whole! has felt in the new banking system. ’’Then President Cleveland, twenty years ago, sent to Congress his message defining the position of this country with respect to Great Britain's attitude on the Venezuela boundary dispute, the leading markets of the country were threatened with collapse. When President Wilson delivered his recent address to Congress with respect to the position of our country on Germany's methods of submarine warfare, though the situation was vastly more delicate and critical, our leading markets showed little weakness and less anxiety, and why? Because there was confidence that, come what might, a we were possessed of/banking organization whose resources and management gave ample guaranties of financial safety. The gratifying evidence thus given of the feeling of security which our new banking system has inspired in the business community, is one of its greatest achievements and most valuable assets, For it may be laid down as axiomatic in modern finance that a financial and banking system, to meet the ultimate test, must not only be strong, but must also be generally believed strong - and adequate to any need. to be That difficult test has been successfully met. Indeed, when we reflect upon the conditions of the past year, the establishment of the Federal Reserve System almost coincidently with the war seems almost to have been providential. Without the new system we should certainly 658 - 51 - have "been floundering like a ship at sea without rudder or compass to guide it; with it we have sailed like a wellballasted ship, steadily and securely. And all this has been accomplished with a very moderate, not to say insignif— icent, amount of activity, as business activity is commonly measured in these days, on the part of the Federal Reserve Banks, thus showing that it is not the amount of business done which measures the usefulness and effectiveness of the Reserve Banks, but the character and the extent of the influence excerted by them, whatever the ways in which that influence may be exerted. With money rates unprecedentedly low, as they have been during the past year and with the banks of the country pretty generally in liberal supply with respect to loanable funds, it is hard to see vhat good purpose could have been served by an attempt on the part of the Reserve Banks to force the use of their funds by demoralizing reductions of rates, even if they could have succeeded, by this means, in diverting business to them selves. I do not doubt that as the natural expansion of bus iness grows up to the supply of credit facilities with which we are now so richly blessed, the loaning power of the Reserve Banks will be drawn upon in increasing degree, and that most, if not all, of the Reserve Banks will have abundant opportunity to engage in activity which will be at once useful to the com munity and profitable to themselves. But until this point is reached, it would be shortsighted to complain because the Reserve Banks, as a whole, have not been dividend-earning in stitutions. Activity is the law of being of any ordinary busi ness concern, but the Reserve Banks are not ordinary business concerns. They have a very aacred place and function in the country's credit system. Profit is not their object, and not, therefore, the test of their fitness. Not the amount of bus iness done., but the amount of good done, is the proper standard by which to judge them. But when this is said or admitted, it should also be added by xvay of a warning word to those who would wish to see the operations of the Federal Reserve Banks circucumscribed within narrow limits, simply in order to avoid the effect of their competition with powerful member banks, that the limited amount of commercial operations in which the ma jority of the Reserve Banks have thus far engaged, is not for a moment to be taken as indicating the range of their normal activity. There will, in time, be much business that these ibanks will have to assist in order effectively to perform their if**-,. 653 - 33 r functions as regulating and governing banks, and while this "business should not he undertaken from motives of profit, we may confidently expect that it will, in the ordinary course, yield returns that will easily pay the expenses of maintain ing the Reserve Banks and meet their dividend requirements, and thus satisfy the ordinary test of "business success along with the other and more difficult tests; for let us not overlook the fact that higher and more difficult tests than axij which the system has thus far had to meet may await it in the un certain and troubled future toward which the whole commercial world seems moving, as a result of the terrific disorganization of industry, commerce, and finance which the gigantic struggle now in progress in Europe will entail. Econimic Readjustment After the War: It has been predicted on the one hand, that the lead ing countries of Europe will find themselves industrially and financially so weakened as a result of the war that they will be long in repairing the damage sustained by their industrial organieation, and will be, in consequence, a factor of diminished importance in the sphere of international commerce. The m©re destruction of large percentages of their working populations ”* ±217 and the disability through injuries and disease, of other large percentages, to say nothing of the destruction of vast amounts of physical capital, it is suggested will result in such shrink age of their productive power as to keep then busy at home for a long tine in repairing waste and loss. The crushing burdens of taxation that will lie heavily upon the connerce and industry of Europe are also pointed to as - factors, that will retard in dustrial recovery. Germany, which before the war occupied a most formidable position in export trade and in. ocean carrying, as a result of British domination of the sea, has been practically shut out from her customary over-seas trade. To what extent and how soon, she 'will recover her former position is regarded as highly problematical, and weakened competition in our markets and some of the new markets in which we have recently been ac quiring a foothold, is, in consequence expected. Others, however, predict that the economic recovery of Europe will be rapid, and that competition, both commercial and industrial, among the leading nations, more intense than has ever before been experienced, is to be expected soon after the close of the war. The animosities, rivalries, and am bitions for commercial and industrial supremacy, which had 1318 658 - 35 much to dc with the making of the war, will., it is said, con tinue and give to the period after the war much of the un settled and unsettling character of war times- Those who take this view predict that an era of protracted and hitter commercial warfare will follow the termination of the armed conflict, and that the differences and scores x^hich were not settled on the field of battle will he fought to a finish on the field of commerce, and that neutral nations will inevi tably he drawn into the struggle. Without undertaking to pass judgment upon predictions of this character, I think it nevertheless well that we should he alive to the contingencies which may he ahead, and I do not hesitate to express my belief that Europe will give tc the world an impressive exhibition of the recuperative powers of modern industry even after such a costly and exhausting war as has been in progress. Stupendous as are the examples that the past year and a half have given us of the destructive agencies of civilization when turned to war, I believe we shall get equally impressive examples at its close, of the construc tive forces of m o d e m civildation when its energies and aspira tions are turned to the healing work of peace. War destroys, •f 658 - 36 "but that is not all that it does- Fortunately for a world in which war is long likely to remain a persistent and recurring fact, war "brings some industrial compensations, though the off set to the losses and injuries be far from complete. War, especially war of the kind which is going on in Europe and touching to passionate intensity the vital impulses of great communities of men, stiffens and steels their fibre and makes them more capable to bear the hard and heavy burden of modern industry, and. therefore will make them more formidable competi tors, in time , of nationa which have not had to face the dis cipline of war. No one can begin to approximate how much the industrial efficiency of the average man and woman in Europe will be raised as a result of the experiences and lessons which war has taught tham in unity of purpose and action, in organ ization and efficiency, in economy and thrift, in industry, and in devotion to duty. These things will tell, and I believe tell mightily, in the productive and competitive strength of the larger European nations after the war. Necessity has already worked some wonderful transformations in the industrial systems of the countries at war, and it is not unreasonable to expect that the nations which emerge from the trenches will, man for man and woman for woman, (for woman is clearly to play a role Q 658 - 37 in the industrial economy of Europe in the future far more im portant than she has in the past) come more near to realizing their full productive capacity than ever "before. This war has also taught lessons to the warring nac tions which will not soon be forgotten or wasted, as to the momentous effect which an efficient credit organization can exert in maintaining a country's industry in a state of health and activity and just as the European credit system has shown a capa city to finance the costs of war which has far outrun the wildest expectation, so it may be expected that it will show a new and enormous power to meet the requirements of industrial recupera tion. Let us not, therefore, make the mistake of supposing that it will be an industrially feeble and unambitious Europe which will emerge from the war. The history of modern commerce affords no parallel to the situation which exists or may exist, and we can there fore learn little from history as to what we may expect. The nearest approach is the long period of economic disturbance following the close of the Napoleonic wars. It took fully fifteen years for the world of commerce and industry to work out the needed readjustments and recover a normal equilibrium, and the process was embittered and embarrassed by policies of ■f 9 0 - 1 , j l _ ■ ”-aa# i" ■<& commercial reprisal and tariff wars, similar to those which » are now being planned by the contending groups in the European war. Neutrality was no protection then, nor wall it be now. Our commerce and industry pursued a troubled course from 1815 to I83 O, marked by a succession of alternating periods of fit ful and feverish activity and industrial breakdowns. The process of readjustment which had to be gone through in order to determine what the relative positions of the several nations should be in the new commercial economy was a long and costly one for each and all. Uncertainty was everywhere. To recognize the possibility, not to say the probability of the recurrence of something similar would seeij* to be the part of prudence forus, and the first step in intelligent preparation for it. The one thing which is certain in forecasting the future is the uncertainty of the conditions writh which we shall be surrounded. Let me add however, in order to relieve unnecessary suspense, that I do not look for an immediate reaction in our industrial situation at large as a result of the close of the war. But I do expect that some of the industries which have been stimulated into frenzied activity by the forced draught of evanescent wrar orders, may have their troubles. Also I -f < 1 )0 0 : _L_■■ks',■'<»/<-y think that there is much danger that their tfcoubles, unless localized and controlled, may breed trouble, uncertainty, and anx.iety for others. as of prosperity. There is a contagion of trouble as well We know this from aad experience. much, at least, may safely be 3 aid; This that our industry and com merce are to travel uncertain and uncharted ways in the years which are ahead, and uncertainty, I need not tell you, is the great bane and foe of modern business. To eliminate it where we can, or to minimize it where we can not completely control it, is our clear duty. We shall not, therefore, if we are wise, neglect to strengthen our defenses so as to make them equal to any contingency with which we may be confronted- And this leads me, in conclusion, to say some frank words to the State banks, whose cooperation should be forthcoming in order to widen the base of our banking structure, to give the country the fullest sense of safety and security. 5* How are State banks meeting their test. Speaking to ahconvention made up largely of State bankers I should be remiss in my duty if I did not avail myself of this opportunity to speak plainly to you. You know that 658 - ko _ % the Federal Reserve Act was purposed planned upon a "broad and generous scale in order that every "bank in the country, whether State or National, doing a commercial "banking business in safe and legitimate ways, might secure for itself and its customers the advantages and protection of the Federal Reserve and at the same time contribute its quota of strength to it. The State banks surpass in number the National banks and repre sent a substantial part of the commercial banking power of the nation. To what extent the proportion has declined since the establishment of the Federal Reserve System can not be approxi mated with accuracy but it is a fact that the National banking system has since the establishment of the Federal Reserve Sys tem shown an accelerated rate of growth and a greater capacity for. growth than State banking during the same period, the in crease in the deposits of the National banks having been esti mated to be three or four times as great as those of the State Banks since the inauguration of the new System. T7hat the relative growth of member and non-member banks will be in the future, I shall not undertake to prophesy but as logg as there is a considerable portion of the banking power of the nation or ganized as State banks and which is eligible for membership in the Federal Reserve System and has not ) oined, the system will not have attained its fullest strength and its widest field of usefulness. 658 -4 1 - VJhy are you State banks not coining in to the new system ? The provisions of the law respecting State bank mem bers are as liberal as could well be desired, and the regula tions which the Federal Reserve Bo.„rd has laid down on this subject are even more liberal. Those of you who have read the Act and the Regulations of the Board will, I believe, find no reasonable ground of complaint. You will find few restrictions upon your customary banking methods. The Board has even gone so far as to provide a way by ’which any State bank becoming a member bank may withdraw from the system in order that you need not be deterred by the feeling that membership means an irrevocable choice. The attitude of the Federal Reserve Board has been founded in the conviction that our new banking system should be as broad raid as strong and as capable, as the financial condition of the country will support and the limitations of the Reserve Act will permit. It is almost a year now since this Board issued its regulations concerning the admission of State banks. Thirty-four banks have joined. The strong conviction which the business community in every part of the land has formed of the benefits of the new system require that it should be known why the growth of State bank membership has been sc slow. 658 -4 2 - Are any of you holding back because of dissatisfaction with the provisions of the Federal Reserve Act or with its administration ? The Federal Reserve Act and the Federal Reserve System are here to stay. They have won the sanction of public opinion and are regarded as the essential bulwark of our financial safety. As to the administration of the Act and of the twelve Reserve Bunks, little but good has been heard. But if the State banks are hold ing back because of dissatisfaction with the administration of the law or the banks, they should make it known in order that the defects may be remedied, and the country given the full advantage of a banking sjrstem carried to the highest point of strength and efficiency. Coming to another reason, I have sometimes heard it suggested that financial conditions have so changed that there is no longer need of the kind of protection and security which the Federal Reserve System was designed to provide. It must be admitted that the financial situation during the past year has been so exceptionally easy that it might well have be gotten in the minds of those who are not in the habit of look ing beneath the surface of things, the idea that financial strain and convulsion is a thing of the past. They are likely 658 -4 3 to experience some surprises, I have already given my rea sons for expecting that the years which are ahead and which will reap the consequences of the financial disorganization and demoralization growing out of the great war, will he years of uncertainty and disturbance for us in common with the rest of the world; years filled with anxiety, and requiring for the good management and the protection of our national interests, the guidance and support of the Federal Reserve System. What ever other mistakes we make, let us not deceive ourselves on this point, and be lulled into a blinding passivity; for when trouble comes, as sooner or later it will and State banks in overwhelming numbers run to cover under the shelter of the Federal Reserve Banks, they may find some difficulty in get ting in as quickly as they would like. There is also a feeling abroad in some parts of the country that in some mysterious way the Federal Reserve System, with the membership of the Ration,al banks', has pro duced a situation in 'which the beneficent effects of the new banking system, like the rains tof heaven which fallalike upon the just and the unjust, will be so inevitably and widely diffused that non-member banks, no less than member banks, will reap the full advantages. Let me say very frankly that I believe there is some truth in this - yes, much truth but not so much as is frequently assumed. —rw r w If To the extent that the success and effectiveness-., of the new system will depend upon the feeling of security that it inspires - in ether words, to the extent that the success of the system depends upon what may be entitled its psychological reserve - it is no doubt true that all the banks, irrespective of their connection with the new system, will participate in the result. But it may readily happen, and it will probably happen, that from time to time - no one can say in the face of the critical years ~hat are ahead of us how frequently these times will occur - the needs which the community will have of the Reserve Banks will call for more than psychological reserves and will at times cut deeply into their gold reserves, and then will it become clear that the strength of the system is measured also by the cash that it holds in hand. The State .bank, therefore, which con ducts a banking, business that qualifies it for membership in the system under the liberal conditions laid down by tho Fed eral Reserve Board, and which sustains relations with the business community of the kind that give rise to financial difficulties and embarrassments of the sort which have called forth the establishment of the Reserve Banks as a means of protecting the community, are taking the responsibility for ■f: < 1 ^ 0 *o 658 -45- themselves and, what is of far more serious consequence, for the communities of customers which they serve, of keeping the new system, from becoming in the fullest sense an American system, equal to any demands that may be made upon it. You are the bankers of a community whicja is served mostly by State banks. Your State has extensive agri cultural, manufacturing and merchandising interests. are precious to your people. They Their condition makes or mars your prosperity and your condition may make or mar theirs. I see no good reason why the people of Missouri, or Arkansas, or Mississippi, should not enjoy in all circumstances the same sense of security as is enjoyed by the farmer, the manu facturer, and the merchant in States or sections of the country which are served preponderantly by National banks. I believe the welfare and security of the Missouri fanner, merchant, or manufacturer was just as much in the mind of Congress when it enacted the Federal Reserve Act as that of manufacturer, merchant, or farmer of Massachusetts or Conn ecticut. He is entitled to all the good that can be reaped from the new banking system and he is entitled to know it, if his existing banking connections do not secure him the fullest end freest access to it. 1 658 -4 6 The Reserve Bank affords an ever ready means by which good commercial paper can, at a moment1^ notice, on presentation at the counters of the Federal Reserve Bank, be turned into either credit or currency. No such thing as a currency famine can overtake the customer of a bank that, by reason of its mem bership in the Federal Reserve System, has the right and ability to go to that bank and get gold, credit or currency. Non-member banks may get it as a matter of favor, but I believe that people as they come to understand these matters more fully, will see the difference between dealing with a bank that, as a matter of right and of course, can go to a Federal Reserve Bank for as sistance in the certain knowledge that it will be forthcoming, and those banks which, if they get such assistance at all, will get it indirectly and as a matter of favor „nd of public spirited generosity on the part of the member bc.nks and of the Reserve Banks. In matters of such vital concern to its industry and agriculture, no community can afford, or will be willing, to pin its faith to bonks which are on the out side of the Federal Reserve System. Those of you who need a more personal and cogent reason for becoming member bonks will soon find it, I believe ± 658 -4 7 - when the plan which has been devised for the clearing and collection of checks has been put into operation by the Fed eral Reserve Banks. The Federal Reserve Bank of St.Louis will soon issue a circular giving complete information and I am confident that the plan will have been in opera tion but a short time before many non-member banks will realize the necessity of joining the Federal Reserve System in order to participate in its new collection plan. The plan is well conceived. The Federal Reserve B~nks will extend unsurpassed collection facilities to such of their members as choose to avail themselves of them, but the system is optional. No member bank will be obliged to clear through its Federal Reserve Bank. The only element of compulsion is that every bank, whether member or non-member, will be obliged to pe.y without deduction checks drown upon it -nd presented at its counter for payment by the Federal Reserve Bank or its representative, either in acceptable ex change or in lawful money. The plan is reasonable: many letters that are coming to the Federal Reserve Board from those who have been the victims of excessive exchange charges prove this. The plan is al3o practicable and is going to 2 3 0 -« <rv f'i 658 -4 8 bo effective : this is proved by the objections that aro being urged against the plan by those banks that are now taking tribute from the commerce and business of the country in the shape of unreasonable exchange charges. It has been estimated that as soon as the plan has been put into opera tion checks upon at least fifteen thousand banks, National banks, State bank3,ond trust companies, throughout the United States can be handled at par through Federal Reserve Banks, subject to a small service charge. the rule. Par collections will be State banks whose checks cannot be collected at par will be a 3mall and rapidly diminishing minority and, as they will find it difficult to retain much good business when checks drawn upon them are at a discount while checks drawn upon the majority of bonks can circulate at par, the day is near at hand when checks upon practically all banks can be handled at par by Federal Reserve Bonks. If the reasons I have advanced for State bank mem bership in the Federal Reserve System are sound, as I believe you will, on sober reflection conclude they are, why, then, I repeat, are you State bankers hesitating and waiting ? 658 -4 9 - I asked this question the other day of one of the largest hankers in this district and his answer as ./'mostof them don’t know. They can’t tell you. But you will get them inquickly enough when trouble comes." I heave spoken to little effect if the logic of my words does not say to you, "Don’t wait ’till trouble comes., but make the assurance of the new banking system for yourselves and % those you serve, doubly secure by coming in now, and doing your part in giving to this country of ours a banking system worthy of its name and worthy of its future." to fail. To falter is, therefore, To fail in this vital test, at this vital time, is unbusinesslike, is ungenerous; is, therefore, un-American and unpatriotic. A. C. M* 5/19/16 -f O 660 SUGGESTED FORM OE REPIY TO INQUIRIES RELATIVE TO THE NEW CLEARING AND COLLECTION PLAN (Prepared by Mr. Harding) The check clearing and collection plan which has been formulated by the Federal Reserve Board is not compulsory upon any bank as far as the use of facilities to be pro vided is concerned. Member banks, as long as they comply with the statutory requirements, may continue to carry ac counts with their approved reserve agents and with other national banks to whom they may send items for collection and from whom they may receive, for similar purposes, checks drawn upon themselves or upon other banks. They will, however, be required to pay without deduction, checks drawn upon themselves and presented at their own counters for payment. Remittance of such checks by the Federal Re serve Bank of their district through the mail will be con strued as presentation at their own counters and they must settle with the Federal Reserve Bank for such checks , either by checks upon other banks or by remittance of lawful .<1 660 money or Federal Reserve notes at the expense of the Fed eral Reserve Bank, Checks drawn upon a member bank which have been received by the Federal Reserve Bank will not be charged against its reserve account until sufficient time has elapsed for the checks to have reached the member bank and for returns to have been received in due course by the Federal Reserve Bank. The Federal Reserve Board’s clearing system provides that a small service charge, based upon the number of items handled, will be made at stated intervals against such banks as send to the Federal Reserve Bank checks on other banks for collection and credit; but it follows that no portion of this charge can be assessed against any bank un less it should elect to avail itself of the facilities of fered. Federal Reserve Banks will handle, besides checks drawn on member banks, checks on such state banks as can be collected at par, and national banks desiring to handle for a Federal Reserve Bank checks drawn on state banks, will be given the preference. During crop moving periods it is 6 60 -3- thought that this will he a distinct advantage to member banks. The Board has no disposition to deprive member banks of any income that they may have been in the habit of re ceiving from the collection of drafts or from the purchase or discount of bills of exchange, and so there should be no diminution in the customary profits of member banks from such sources. The Federal Reserve Board has received many letters in regard to the plan, a great number of which are com mendatory, and it appears from those of opposite tenor that the objections raised are based upon an apprehension that profits will be decreased and upon the feeling that the plan will prove to be effective. It is estimated that as soon as the new clearing system is put into operation checks upon about 15,000 national banks, state banks and trust companies throughout the United States can be handled by the Federal Reserve Banks at par, subject to the small service charge above referred to; and as a minority of the 1.256 # • 660 -4- banks will find it difficult to retain much of their good business when checks drawn upon them are at a discount while checks drawn upon the majority of banks can circulate at par, it is thought that in the near future checks upon practically all banks throughout the United States can be handled at par by Federal Reserve Banks. Many banks have found it advisable hitherto to concentrate their available funds by maintaining balances with a number of correspond ents for exchange purposes, or in order to control checks drawn upon themselves. After November 16, 1917, no bank balances will be available as reserve for national banks except balances in Federal Reserve Banks, and therefore * after that time any necessity to maintain non-reserve balances with correspondents, either for exchange purposes or in order to obtain collection facilities, would be deemed in many cases a great hardship. It is thought that in numerous instances banks will find it expedient to concen trate their balances and to close many of the accounts which they now carrj* with other banks, and that a system which will enable them to send all of their checks on other banks 660 -5- to Federal Reserve Banks for exchange purposes or as an offset against checks on themselves forwarded by the Fed eral Reserve Bank, will, in course of time, come to he appreciated as a convenience and the release of funds heretofore tied up in accounts carried with other hanks and their employment at higher rates of interest in com mercial loans, should offset to a great degree the pro spective loss of exchange profits which is at the present time looked upon with apprehension by some of the banks. ■* WPGH-RRB-5/19/16. W. P. 6 . HARDING, GOVERNOR PAU L M. WARBURG, VICE GOVERNOR FREDERIC A. DELANO ADOLPH C. M ILLER CHARLES S. HAMLIN EX-OFFICIO MEMBERS W ILLIAM 6 . McADOC SECRETARY OF THE TREASURY CHAIRMAN JOHN SKELTON W ILLIAM S COMPTROLLER OF THE CURRENCY FEDERAL RESERVE B O A R D H. PARKER W IL L IS . SECRETARY SHERMAN P. ALLE N , ASST. SECRETARY AND FISCAL AGENT W A S H IN G T O N ADDRESS REPLY TO FEDERAL RESERVE BOARD 665, May 24, 1916. Dear Sir: For your information I beg to enclose copy of order entered by the Board, in the matter of the petition of certain banks in Wisconsin for change in the geographical limits of Districts Nos. 7 and 9. The Board has given careful consideration to the views presented and has reached the conclusion that it would not be justified in making any alterations at this time. If future developments should, indicate any neces sity for such change the Board will, at a later date, give consideration to the matter upon the application of banks desiring to be transferred. The Board, however, is very hopeful that the results under the new clearing system will make a transfer unnecessary. Attention is particularly called to the fact that if the Board had granted the petition as filed, those bsinks located in that portion of the Minneapolis District em braced within the upper peninsula of Michigan would have been isolated and cut off from the rest of the District. This fact should be taken into consideration if, at a future date, an amended'petition is filed for modification of the district lines. Very truly yours, Vice Enclosure. Governor. ■n 666. IN THE MATTER OP THE PETITION OF CERTAIN BANKS IN WISCONSIN FOR MODIFICATION OF DISTRICTS NOS. 7 AND 9. Upon consideration of the petition of certain banks in Wisconsin that the geographical limits of Districts Nos. 7 and 9 be modified ao as to include in District No. 7 a part of the ter ritory now included in District No. 9, and After a full investigation of the matter and in view of the fact that the petition if granted would have resulted in isolating and disconnecting the upper peninsula of Michigan though leaving it in the Minneapolis District, the Federal Re serve Board has arrived at the conclusion that there is no pre sent necessity for any change in the geographical limits of the said Districts Nos. 7 and 9 at this time. It is ordered that said petition be dismissed without prejudice to the rightsof the signers to file an amended petition at a later date. 5/24/16. o o q IN THE MATTER OF THE PETITION OF CERTAIN BANKS IN WISCONSIN FOR MODIFICATION OF DISTRICTS NOS- 7 AND 9, Upon consideration of the petition of certain banks, in Wisconsin that the geographical limits of Districts Nos. 7 suid 9 be modified so as to include in District No. 7 a part of the territory now included in District No. 9, and After a full investigation of the matter the Federal Reserve Board has arrived at the -conclusion that there is.no present necessity for any change in the geographicsil limits of the said Districts Nos. 7 and 9 at this time. It is ordered that said petition be dismissed with out prejudice to the rights of the signors to file an amended petition at a later date. 5/25 A 6 'IP* W. F. 8. HARDIN6. 80VBBB0B PAUL M. WARBUN8. VICE SOVIRHOR FREDERIC A. DELANO ADOLPH C. MILLER CHARLES S . j ! ^ y i EX-OFFICIO M IM IIM WILLIAM 8. NCADOO SRCRRTARY OF THB TRR ABIIRY CH AIBH AN JOHN SKELTON WILLIAHS COMPTROLLER O F THE CUBBBBCV FEDERAL RESERVE B O A R D H. PARKER WILLIS. SRCRRTART SHERMAN P. ALLEN. ASST.SECRETARY AND FISCAL AORRT WASHINGTON May 24, 1916. Mr. J. Z. Miller. jr.. Governor, Federal Reserve Bank, Kansas City, Mo, My de'ar Mr. Miller: In answer to your letter cf May 19th it is not the thought of the Comm.'.ttoe oh Clearing el the board to take up at this time the question of charges which member hanks are to make, against their patrons and, therefore, the matter has not been discussed vy the Board. Gu:* thought was that we should first get the matter of par collections working, and . then we could see what further it was necessary to do. It is conceivable, for example, that a member bank mig^t pay only lil per item to get its checks collected and be Obliged in addition to allow enough time for the collec tion to be effected before it could draw on the fund, and then turn around and charge its patrbns an exorbitant charge, but Z think this is rather Unlikely; As you very well know,. the &igh exchange charges in the past by country banks have been made by country banks against the large city banks, who sent them the items, and this .system would never have been effective if there had not been an arrangement, or community of interest, between the' country bank and its city -bank correspon dent. 1242 667, - 2 - In the big cities it is true that the city banks have followed the custom of charging exchange on out of 'town items, but out. wq believe that competition is pretty likely to rub this At any rate, it seems to Mr. Harding and mysglf that we had better do one thing at a time and see what happens to collection charges. So far as the service charge to be made by the Federal Reserve Bank is concerned, we are perfectly willing that it should be li^ per item, and we do not object to 2^ per item to start with in Districts like San Francisco and Dallas. Perhaps after a few months’trial a different basis will be found desirable, one possibly based on gross amount as well as on items. Yours very truly, F. • DELflr?4 Vice Governor. W. P. G. HARDING. GOVERNOR PAU L M. WARBURG. VICE GOVERNOR FREDERIC A. DELANO ADOLPH C. M ILLER CHARLES S. HAMLIN Ex -O ffic io Members W ILLIAM G. McADOC SECRETARY OF THE TREASURY CHAIRMAN JOHN SKELTON W ILLIAM S COMPTROLLER OF THE CURRENCY FEDERAL RESERVE G O A R D H. PARKER W IL L IS . SECRETARY SHERMAN I V A f- U p N . ASST. SECRETARY WASHINGTON ADDRESS REPLY TO FEDERAL RESERVE BOARD AND KfecfcO AlSEN T Mav 23, 1916. Mr. J. B. McDougal, Governor, Federal Reserve Bank, Chicago, 111. My dear Mr. McDougal: Answering latter signed by Mr. McKay wider date ol May 15th, as you have already been informed, the Federal Re serve Board is in general accord with the resolutions adopted at the Transit Managers’ meeting as to the matter of details. This is true, generally speaking pf all the resolutions with the exception of that in respect to developing the clearing opera•tion in three stages instead oi one. After hearing from all of the Federal Reserve Banks the Board concluded, as per our tele gram of May 21, to direct the starting of the elfcaring system generally on Saturday, July 15th; thirty days later than the date set forth in our Circular of May 1st. There are a few matters, however, to which you have specially called the atten tion of the Board and these, after some discussion yesterday were referred to the Board’s committee on clearing. The first subject is that of par lists of non-member banks for each District, which is touched upon in Topic No. 6. Our committee entirely approves the conclusions arrived at by the Transit Managers and will be very glad to cooperate in any way it is desired in having lists printed by the Government 668 - 2 Printing Office for the use of the member banks. . In this con nection, however, we want to call attention to the fact that it is important that the committee having this matter in charge shall send us "copy1' and “form" showing us exactly the style which is to be followed, and requisition stating the number of copies desired. With reference to your Topic Ho. 10, entitled, "Penal ties for Encroachment upon Reserves", the Board sees no objec tion to the rule suggested by the Transit Managers. Topic No. 11: Analysis of Per Item Cost: We see no objection to this basis of analysis. There are one or two other topics not specifically mentioned in your letter to which the committee would call attention. Topic No. 3, entitled, "Sorting of Items by Member Banks", the resolution of the Transit Managers requires all member banks to sort their items in accordance with the time schedule. It appears to us this is entirely proper with banks of considerable size, but would be burdensome with small banks. In deciding what you should do in a matter of this kind we think you should certainly not be more exacting than large city banks have heretofore been in their requirements upon country correspondents. - Indeed this is a rule which might, we think, be based on the number of items sent. i OJ.5 . 3 . 668. Topic No. 9, entitled, "Statements of Reserve Re quirements from Member Banks." The resolution asks that a statement be required from member' banks at least once a month, showing the average reserve requirement for the preceding month. It is obviously impossible for a member bank to fig ure the averagq reserve requirement unless it tabulates the daily net demand and time deposits and from the sum of these calculates the average. Asking, for the average will result in many cases in getting simply a shrewd guess as to what that average really is. It appears to us that the way to get this information accurately with the least labor on the part of the banks is to ask the banks to give you, either weekly or monthly, a statement showing their daily demand and time deposits, from which a clerk with an adding machine can quickly determine the average. The comit tee offers this simply as a suggestion which should have your consideration, especially in view of the fact that three of the Reserve Districts are now requiring such statements from their members. Topic No. 12, "Method of Applying service charge to number of items." The Transit Managers recommended a uni form charge not exceeding per item. We understand, how ever, that in the Dallas and San Francisco Districts the Fed eral Reserve Banks believe that they must charge at least 2<ji as compensation. Hie Federal Reserve Board’s coranittee •)1 O "'I ! 668. 4 believes that, while it Is desirable that the charges should bo as nearly alike as possible, it is not essential that they should be identical* It has occurred to our committee that you might like to determine that this charge of lg# might bo split ao as to divide the compensation in some cases. for example, a bank in the Seventh District As might send Chicago a lot of items on the Cleveland District, or it might send them direct to Cleveland. If the Cleveland Bank is paid the whole 12^ per item in each case, there is nothing left for the Chicago Bank for its service. If, in this case, the Chicago Bank should receive lir^ per item and pay the Cleveland Bank some thing less than lg$ for collecting items, it would receive some compensation for its share in the service. It may be thought cumbersome and unnecessary to do this and the Board’s committee does not.care to press the point. After experience of several months it may be deter mined best to put.the charge on some different basis or to make allowance for the gross total of items as well as their number. Yours very truly, F. A. DELANO ’.T: • • * ) ) Committee W. P. G. HARDING ) on Clearing. A copy sent to. the Governors of each Federal Reserve Bank. Ex -O ff ic io MEMBERS W. P. G. HARDING. GOVERNOR PAUL M. WARBURG. VICE GOVERNOR FREDERIC A. DELANO ADOLPH C. MILLER CHARLES S. HAMLIN WILLIAM G. MCADOC s e c r e t a r y o p the Tr e a s u r y C h a ir m a n JOHN SKELTON WILLIAMS FEDERAL RESERVE B O A R D COMPTROLLER OF THE CURRENCY H. PARKER WILLIS. SECRETARY SHERMAN P. ALLEN. ASST. SECRETARY A N D g ^ U g . A6ENT WASHINGTON ADDRESS REPLY TO FEDERAL RESERVE BOARD May 26, 19X6. Mr. D. C. Wills, Federal Reserve Agent, Cleveland, Ohio. My dear Mr. Wills: The point raised in your letter of $ay 12th, reading as followte: "Will the country bank keeping a single account be permitted to count the full balance in that account without deduction, as reserve, provided it carries on the books of the Federal Reserve Bank a net collected balance equal to its minimum reserve requirement?" is a matter which we have not as yq>t dealt with. It is really a matter for the Comptroller of the Currency to decide and we have not wished to urge a change in the Comptroller's ruling. As far as the Federal Reserve Board is concerned, it can only deal with the minimum reserve requirements in the Reserve Bank. The optional reserve and the reserves in the member banks* own vaults is a matter between the member bAnk and the Comptroller. * If the Comptroller continues to allow member banks to count a|i reserve items which have beei^ put in the mail for collection that ii his lookout. If he allows banks to more than offset items due to other banks, with‘items due from other banks, but not collected, that is beyond the control of the Federal Re serve Board. 672. - 2 ** My own view, furthermore, is that while' we must he conservative we must take our steps one at a time, and that it would he a groat mistake, simultaneously with the adoption of the clearing plan, to cause the adoption of a harsh ruling by the Comptroller as to how member banks* records of reserves are to be interpreted. This is a statement which we are not "shouting from the housetop", nor one which we would include in any circular, but I believe that it has an important bearing in the successful working out of the clearing plan. Since dictating the above I find this matter stated rather well in the circular of the San Francisco Bank to its member banks, one paragraph of which reads sis follows: "While the proceeds may not be counted as required reserve deposits (i.e., the amount required by the Fed eral Reserve Act to be carried unconditionally .on deposit with Federal Reserve feahk), yet, because credited by Fed eral Reserve Bank, they may be counted as part of the optional roseryes (i.6., the amount to be carried either ixk member bank‘e own vaults, with Federal Reserve Bank or with other approved reserve agents)." .Yours Very truly, Vice Governor. ADDRESS OR W. P. G. HARDING, MEMBER OR 'THE FEDERAL RESERVE BOARD, BEFORE THE ARUM I SOCIETY OF THE UNIVERSITY OF ALABAMA, AT TUSCALOOSA, TUESDAY MORNING, MAY SO, 1916, RELEASED TO AFTERNOON PAPERS, MAY 30th. EFFICIENCY AND INDUSTRIAL PREPAREDNESS. We are celebrating the one-hundredth anniversary of the historic city of Tuscaloosa and the eightyfifth annual commencement of our great University. Al though upon such an occasion our thoughts naturally take a retrospective turn, I shall not in my remarks dwell upon the past, rich as it is with lessons of its trials and triumphs, nor will I pose as a prophet and attempt to rent the veil of the distant future. I shall speak instead of the present and of that im mediate future which lies within our horizon, and which we can make \?hat we will. (I.) LESSONS OF THE EUROPEAN WAR. We are living in a most critical period of the 1250 - 2 - world's history, a stupendous era, full of opportunity and fraught with gra^e responsibility. The frightful holocaust on thh other side of the Atlantic, with its appalling sacrifice of human life, with its enormous waste and with its pandemonium of calamity and woe, has aroused in the hearts of the people of this country mingled feelings of horror and of pity, but also it has instilled in our minds a better and higher appreciation of our duty to ourselves, to our country and the world. Ho longer are we lulled into a false sense of security because of our splendid isolation, no longer do we feel that we enjoy permanent immunity because of the three thousand miles of ocean waves that separate us from the shores of Europe; but we have as a nation come to realize that our surest guaranty of peace lies in pre paredness for war. The first steps for military and naval preparedness have already been taken, and because of this we are confident that we shall escape any part of the tragedy now being enacted on the three continents of the old world. This confidence is intensified be cause of the calm judgment and consummate skill of the President of the United States, Woodrow Wilson, who has fOKI -3- so successfully handled a grave, international crisis, maintaining friendly relations, while preserving our national honor and dignity. It is not necessary, there fore, to discuss at length at this time and place, pre paredness from a military sense, but it is well that we should consider it from a commercial and industrial standpoint. f II.) EFFECT OF WAS UPON AMERICAN COMMERCE. Out of the misfortunes of others has come to a great extent the marvelous prosperity with which this country is blessed today. The temporary depression in the United States which followed immediately the out break of the war and which was due to the sudden and com plete collapse of credits and to the interruption of the accustomed means of transportation and communication throughout the world, was followed by a speedy readjust ment which brought with it from the warring nations and from non-combatant countries ?/hose trade had been prin cipally with the powers at war, millions upon millions of dollars worth of orders, not only for munitions but also for the ordinary necessities of life, v/hich have been pouring in upon this country so that it has been -4 - enriched, according to the estimate of some authorities, to the extent of about three billions of dollars. This golden flood has fairly deluged some of the states to the north and west of us. Alabama and her sister states of the South, while feeling to some extent the impetus of better times, have not received their fair proportion. fill.) POSITION OP THE SOUIHo The South, since that day, back in 1881, when we members of that Glass made our final bows upon the ros trum in Woods' Hall, has made great progress in all lines of industry, in agriculture, in manufacturing, in mining, in banking and in commercial pursuits, as may be exempli fied by the statement that the banking power of the Southern states is now greater than that of the entire United States at that remote day. But our section, never theless, has not yet become highly specialized in the arts and sciences, and in manufacturing, but is still es sentially an agricultural region and still has cotton as its principal money crop. Because of the inability of the central powers to import cotton on account of the rigid blockade which is being maintained, the South has, during the past year, been deprived of a market for nearly one-fourth of its export crop, so that neither its -5 - manufacturers nor its farmers have reaped that measure of profit which has come to the same classes in other sections. The South is, however, an important part of the United States, and is interested in common with all other sections, in the maintenance of national pros perity. Already there are some indications that a wearied Europe is beginning to turn its thoughts toward peace, and perhaps it may be the mission of our Southern bom President to poipt out the way. (IV.) AFTERMATH OE THE WAR. Restoration of peace will necessarily bring about important changes in the world’s trade and just what these changes will be and how they will affect business conditions in this county, are problems which are being studied carefully by publicists and business men. These are vital questions here in the South as in other parts of the country, although we may not be as directly af fected as other sections for the reason that a smaller part of our business has come from foreign countries or has been connected with war material. Wo should, how ever, stand ready to support the Government in any measures that it may be necessary to adopt in order to retain the legitimate foreign trade that we have already \254 -6- secured, to extend still further our business intercourse with South American countries, besides maintaining a proper balance in our trade relations with the nations % now at.war« American bankers are permitted under the Federal Reserve Act to establish branches in foreign countries qnd can thereby facilitate transactions involv ing the importation or exportation of goods, and it is practically certain that a law will soon be on our statute books creating a tariff commission, whose duty will be to make a close study of changing conditions and to recommend from time to time such modifications of our present tariff laws as may be advisable. I do not speak authoritatively, but I hope that as a measure of commercial preparedness, steps will be taken to encourage the manufacture of dye stuffs in this country, to pro tect American firms against foreign dumping and to pro vide heavy penalties for foreign concerns engaged in un fair competition in the United States. American merchants and manufacturers seeking to compete with those of other nations in the markets of the world should be permitted to engage in the contest on equal terms with their com- . petitors, and we should, therefore, favor some arrangement <! O K K -7- that will enable American exporters to secure foreign trade in competition with the cartels and combinations of Germany and other countries. • (V. ) AMERICA! MERCHANT MARINE. A serious drawback to the development of our foreign trade is the utter inadequacy of our American Merchant Marine. The South has felt this perhaps as keenly as any other section of the country. We have been handicapped very greatly in exporting cotton by lack of ship room and by abnormally high ocean freights. Rates to Liver pool on cotton have for several months past, frequently ruled as high as $>15*00 per bale, or Z</ per pound, or about 10 times the normal rate, and this excess has, to a great extent, come out of the pockets of the Southern farmer. American ship yards have been very busy for the past year or more, as private capital has been attracted to shipping by the unusual profits obtainable, but in normal times this activity cannot be expected to cont inue. Our wage scales are much higher than those of foreign countries, whose shipping is also, in many cases, subsi dized, and, in order to establish an American Merchant Marine which can be used in the carrying trade in time of peace and as a naval auxiliary in time of war, Government intervention and aid seems necessary. The shipping bill passed the House of Representatives a few days ago, with the support of practically all the Southern members, and will, in all probability, pass the Senate and become a law before the adjournment of Congress. (VI.) RURAL CREDITS. Another measure of supreme importance to the South is now in conference, — the rural credits bill. The South for a great many years has labored under the curse . of absentee landlordism and it has suffered from the evils of the tenant farming system. Hardly more than a •i tithe of its productive capacity has been utilized, for lack of both capital and labor. With the exception of Texas, the Southern states have not attracted their proper share of immigration, either foreign or domestic. Too many of our rural population have found it impossible to make any substantial headway, and finding themselves year after year lacking all of the lunuries and many of the necessities of life, have lost ambition and have 1257 -9- settled down to breathe the sodden atmosphere of a hope less and aimless existence. The rural credits act will open the way for the organization of national farm loan associations which, in cooperation with the twelve Federal land banks to be 'established, will make loans on farm lands on long time; payments being amortized so that the total annual installment, including interest and reduction of principal, will amount to not more than Q% exceed of the principal, the interest in no case to 6%. Land owners will thus be afforded an op portunity of improving their farms by ditching, fencing and by the erection of silos and buildings, diversifica tion of crops will be encouraged, cattle raising will be promoted, and the thrifty tenant farmer will be given an opportunity of becoming his own landlord. Many who have heretofore been without hope or definite ambition, will find a new incentive to work and to accumulate with a view to ultimate independence. Southern agriculture will thus receive a wonderful stimulus, and many of the young men growing up on the farms whose ambition now is to go to a town, will find it to their advantage to make a study of scientific farming and to practice it as a -1 0 - life vocation. Better living conditions in farming districts and greater prosperity for the farmer mean decreased cost of living, less concentration of popu lation in the towns and cities, more schools, letter morals, and a happier and more contented people. Pros perity on the farms means larger orders for the mer chant, the coal operator, the lumberman and for the manufacturer; more business for the railroads, steadier employment of labor, increased deposits for the banks and a greater demand for loans. Consider what Europe has done for its farmers and how, up to the outbreak of the deplorable war, it had improved their condition, and how the continental powers have been able, through scientific farming methods, to support themselves during abnormal conditions. While the methods adopted in Europe may not be best adapted to the United States, surely with some modifications they can be made effective here. Nearly one hundred and fifty years ago, Oliver Goldsmith wrote his greatest poem, lage." ’'The Deserted Vil It was a striking exposition of English history and a remarkable forecast of the future. -1 1 - "111 fares the land, to hastening ills a prey, Where wealth accumulates, and men decay; Princes and lords may flourish, or may fade; A breath can make them, as a breath has made; But a bold peasantry, their country's pride, When once destroyed, can never be supplied, A time there was, ere England1s griefs began, When every rood of land maintain'd its man: for him light labor spread her wholesome store, Just gave what life required, but gave no more; His best companions, innocence and health, And his best riches, ignorance of wealth. But times are alter'd: trade's unfeeling train Usurp the land, and dispossess the swain; Along the lawn, where scatter'd hamlets rose, Unwieldy wealth and cumbrous pomp repose, Anjp: every want to luxury allied, And every pang that folly pays to pride. Those gentle hours that plenty hade to bloom. Those calm desires that a s k 5d hut little room, Those healthful sports that graced the peaceful scene, lived in each look, and brighten'd all the green; These, far departing, seek a kinder shore, And rural mirth and manners are no more." Have we not in American been drifting into the conditions so graphically described? let us never lose sight of the fact that farming is the most important industry in the world. Without the farm all other business would stagnate and die, the railroads would cease to run, the hanks and mercantile establishments could no longer operate, and grass would grow in the streets of our cities, which would no longer he thriving marts of commerce but would become, through famine, whited sepulchers of the dead. Ho other business can succeed without the farmer, hut the farming business can sur vive, if left unfettered, without the aid of any other businesso (VII.) WATER POWERS. let us now consider for a moment the subject of water. For some years past, we in Alabama have heard a great deal about another liquid, and I am sure that it will be refreshing to turn our thoughts to pure and unadulterated waters We need not discuss its superla tive merits as a beverage or as a cleansing agent, but rather let us consider its utility as a means of trans portation and as a source of power. Bountiful nature has favored our State in the matter of waterways. Through the Warrior, the Tombigbee, the Alabama and the Coosa, the waters springing from the hills in the mineral regions flow through rich agricultural sections and discharge themselves into the Gulf of Mexico. The work of nature has been supplemented by the national Government and by means of locks and dams on the Warrior and Tombigbee Rivers, perennial navigation h^s been provided from the coal fields to the Gulf. Already '. i -13barges laden with black diamonds pass every day down the river Just below the University, bound for Mobile and New Orleans. Through a beautiful valley in northern Alabama, flows the great Tennessee River, a majestic stream which springs from the mountains of North Carolina and Virginia, and flowing through east Ten nessee, enters our State near its northeastern corner, and leaving it at its northwestern extremity, turns again through Tennessee and, passing through Kentucky, unites with the Ohio and finally discharges its waters into the mighty Mississippi. Most of this wonderful stream is already open to commerce, through Alabama, but in its course its waters plunge through a series of shoals and rapids, known as Muscle Shoals, which i. block navigation, but which, if properly harnessed, will -I furnish one of the greatest water powers in the United States. Locks and dams at Muscle Shoals would render the Tennessee River navigable from Knoxville to Paducah, and would, at the same time, offer to in dustries electric energy of approximately 500,000 horse power. When we speak of Muscle Shoals, there results a triangulation of ideas. On one side is transportation, :0 -1 4 on another the fertilization of oar farms, and on the third, military preparedness, We all know that nitre, or saltpetre, is an essential ingredient in the manu facture of gunpowder and of fertilisers, and that the world1s great natural deposits of nitre are in north ern Chile. We know furthermore, that the oxygen in the air we breathe is heavily diluted.with nitrogen, and that science has found the way, through mechanical means, of accomplishing the fixation of air nitrogen into nitrates, The marvelous efficiency of Germany as a nation is admitted by her friends and enemies alike, by her sympathisers and by her critics. Some years ago German manufacturers began, under adverse conditions, the manufacture of nitrates from the air. When I refer to adverse conditions, I mean that this process of fixation requires enormous power and calls for a tremendous expenditure of energy; and in a country like Germany, having no great water powers, this energy can be supplied at high cost only by the con sumption of an enormous amount of fuel. I understand that not less than 300,000 horse-power must be pro duced in order to manufacture air nitrates on a commercial scale, and the only nitrate manufacturing plant on the American continent is located on the Canadian side at Niagara Falls. The bill that has recently passed both houses of Congress to increase the efficiently of the military establishment of the United States, recognizes the necessity of an ade quate nitrate supply and empowers the President of the United States to make such investigation as he may deem ' to be necessary to determine the best, cheapest and most available means for the production of nitrates and other products for munitions of war and useful in the manufacture of •fertilizers by water power, and he is further authorized and em powered to ’"designate for the exclusive use of the United States, such site or sites upon any navigable or non-navigable river, as may, in his opinion be necessary to carry out the purposes of the Act, and he is further authorized to construct, maintain and operate, at any site or sites so designated, dams, locks, improvements to navigation, power houses, and other plants and equipment, or other means than water power as iij his judgment is the best and cheapest, T f -16- necessary or convenient for the generation of elec trical or other power and for the production of ni trates or other products needed for munitions of war and useful in the manufacture of fertilizers and other products*TT The hill furthermore appropriates the sum of twenty million dollars, available until expended, to enable the President of the United States to secure this nitrate supply. I do not know what recommendations the War Department will make to the President, nor can I predict what his choice of a site will be, but I do know that no site in the United States is superior to Muscle Shoals from the standpoint of strategic location, the power that can be generated and the proximity to large deposits of phosphate rock. I wish that I were a word painter, so that I could picture to you.the great opportunity that is presented to the people of Alabama, and the far reaching results that would come from the location of this nitrate plant within the borders of our State. Imagine a gigantic dam across a broad and majestic river, a great power house, and beyond, a nitrate, plant, on one side of which will be built a large factory where nitric acid will he produced for use in the manufacture of explosives; on the other side works for the production of ammonium phosphate, where the phosphate reck brought from nearby fields will be combined with the nitrates and converted into that important ingredient of all commercial fertilizers, ammonium phosphate. The waters of the Tennessee in thei'r ceaseless flow toward the Ohio and the Mississippi can generate at a minimum cost after the initial expenditure has been made, the large amount of power necessary for the operation of these plants. This power, contrary to the fears of many, would not inter fere with the consumption of Alabama coal, for it would develop an entirely new indiistry which cannot he es tablished if dependent upon coal as a fuel. I wish that I could picture to you the other important indus tries that would follow the establishment of this plant, such as electric furnaces for the manufacture of the finest grades of steel, establishments for the production of aluminum from the vast deposits of bauxite which abound in east Alabama. I would point out to you the wonderful opportunity that would thus be - 18- opened to the young men of Alabama, and I can see in my mind's eye a great school of technology here at the University, where future generations can be taught the principles of efficiency and of applied science, which have done so much for the development of Germany during the past forty years. Surely every man of influence in Alabama will do all in his power to induce the presi dent to locate this plant on the banks of the Ten nessee. Many other states have eligible locations to offer, though none in my opinion can at all compare with the one at Muscle Shoals. Every possible in fluence will be brought to bear by these states to pre sent their own locations in the most favorable light, and it behooves the people of Alabama during the next few months to work as they have never worked before, if we wish to win this great prize, which would mean an immediate expenditure within our borders of twenty million dollars, with industries to follow which will cost at least thirty millions more. (VIII.) DEVELOPMENT OP ALABAMA'S RESOURCES. There has been too much talk about the great natural resources of Alabama. Thr time has come for 4 f -19- act ion l We must develop them! About two months before the surrender of the armies of the Confederacy, a con ference was held by Abraham Lincoln with three. Con federate Commissioners, at Hampton Roads. I do not know whether it is history or whether it is fiction, but the story is that at that conference Mr. Lincoln, holding a sheet of white paper in his hand, said to Alexander H. Stephens, "Let me write Union on this paper and you may write whatever else you please." If this story be founded on fact, what an opportunity for the South was lostI If we could bring the people of Alabama to a proper realization of the importance of hard work, of constant and unflagging effort and of efficiency in work; if we could be justified in taking a map of Alabama and in writing across that map in outstanding letters reaching from the Tennessee to the Gulf, and ) from Georgia to Mississippi, the word "Efficiency," we would have a great and prosperous State no matter what else might be written there. In the South today, our economies as a rule are neither scientific nor potentially efficient, nor do our activities contribute to stop waste and to increase efficiency. We find 1 2 6 * -2 0 - .waste and. more waste everywhere. We have made only a beginning in the manufacture of by-products,— we can see in half a dayTs journey, thousands of coke ovens, illuminating the midnight skies with flames which con tain many elements of wealth, but which are absolutely thrown away. Because of the nitrogen which it contains, a million tons of cotton seed meal is put back every year into the soil of the cotton fields of the South,' although overhanging every acre there are over thirtythree thousand tons of atmospheric nitrogen which the water powers of Alabama now going to waste could take out of the air and fix ready for use as a fertilizer for increasing our production of agricultural staples. (IX.) EFFICIENCY VERSUS WAS IE. But waste and inefficiency are not to be found alone in agriculture. They are found in the forest and in the factory, as well as on the farm; in mechanical arts and in scientific achievements we lag behind. The Secretary of the Navy, a Southern man by birth and rearing, of ardent Southern sympathies, recently se lected twenty-three engineers and scientists as a civil naval advisory or efficiency board, not one of intoom was taken from any activity or association of the Southern 1 L.. ’Ns# i £ - 21- states. We are proud of our traditions, yet we have ! seen other states forge ahead, even the arid states in the rainless regions of the west, which have in twenty years secured from the Federal Treasury one hundred and sixteen million dollars for the accomplishment of their irrigation projects. We are afflicted too much with traditions, resignation, efficiency. indifference and in Too many of the sons of Alabama have left their paternal roof-trees and have sought their for tunes in other states. We must do something, not only to make it to the interest of the young men of Alabama to remain at home, but something that will induce the best elements of the citizenship of other states to cast their lot amongst us. According to a poetic fancy the name ’’Alabama” signifies "here we rest.” It is too bad that any should think this means ’’here we do n o t . work; here we take our ease," and we should seek to justify the construction of the word ’’rest” as meaning "remain;" so that the name of Alabama henceforth shall signify, as a matter of choice, and because of the glorious opportunities offered, here we remain." "hence we will not go; 1270 681. RELEASED FOR THE EVENING PAPERS OF FRIDAY, JUNE $. Address of Hon. Paul Mi WaTburg before the Convention of the New Yof*k State Bankers! Assn., Atlantic City, IT* j., June 9, 1916. The federal,reserve system and the banksA-^ucc^ssful solution of Federal Reserve problems is dependent equally upon a thorough, under-: standing of the many features of detail involved in the technique of banking end upon a strong gra:Jp of the big and fundamental objects for the accomplishment of which the system was created. It is, therefore, a pleasure to address an audience that is certain tc have a keen and sympathetic interest in both of these phases of the problbmi I an. particularly anxious, however, to speak to you.about ths broader and more fundamental questions involved, for there is an indefinite feeling of appre hension in my mind that at thi3 time we may be losing the big point of view of financial statesmanship, and that petty and technical questions may be claiming per haps, too much of our consideration. ±271 681 -2- Miile in South .America, I had ah oppor tunity to get a bird1 3 dye-view of the operation of the Federal Reserve System* \ With the keenesi i .enjoyment and pride I daw our system hitting its mark many thousands of miles away, and became deep ly impressed that we are*now firmly establishing ourselves as a great financial power in the world1s .market* Upon my return^ I felt a very chilling change of atmosphere, vdicn I eb t .American bankers appearing to hold the view that the future of our great monetary and banking system depends upon the question -whether or not * a country bank might charge exchange of one-tenth of one per cent when remitting for checks drawn on itself l . The banking system of a world power can net possibly be c 021straced upon so small a founda tion.’ I still remember that, when I had my first training in banking in Hamburg, thirty years ago 1372 my dear old father*j mind strongly rebelled agdihst what he considered then the new-fashioned idea of oemg repaired *• not by the government, indeed* out by the general law of competition -» to discon tinue the practice of charging a small commission when remitting for checks or maturing bills drawn on his banking firm* But he socn perceived that the eotablisbment of a general transfer and clear ing oy*tem, postal orders and postal checks^had made for new condition and that the development of a discount system based upon modern pnncipleo of banking, \hile breaking down certain petxy revenues, was bringing about a tremendous increase m the volume of buoiness. As a result, he soon waived his objection*) and lent his hand in turning his country from provincialism into an international banking power. ago. That, as I oaid, was thirty years 1273 1 have Ac doubt that this country has de cided that it is entitled tc ac modern a banking system as the rest of xhe wofla, and that whatever old-fashioned privilege still blocks the fcath will have to fall by the wayside- Tty0 sacrifice will have to be borne for the general good and will find its compensation in the freer economic de velopment of the country. One of the most tangible results of the operation of the Federal Reserve System is tns establishment and growth of the American bank ers* acceptance business. In addressing a group of bankers, it is unnecessary to dwell at length upon the fundamental importance of this development for the general safety of our banking system. We have now a substantial market for bankers* acceptances to which all member banks will look for the.investment of same of their idle means and in which, at any \ • time* they itiay reconvert these holdings into liquid funds* The more important this market grows, the stronger will be the position of the Federal Reserve Banks, for the greater or lesser volume of purchases of such acceptances will offer one of the Federal Reserve Banks' most effective means of exercising a wholesome influence upon the fluctuation of interest rates. A3 normal conditions are reestablished in the world, this acceptance market will become an important fac tor in protecting our exchange position with foreign countries and, incidentally, our gold holdings. It has taken some'time to develop this market, but I am confident that, from now cn,its growth will be rapid. One of the ob stacles that made-the start difficult was found in the fact that many acceptances, uhich are made for the purpose of financing importations . T 6 - and exportations, have to he drawn and sold in foreign countries. . In order to make them nego tiable in those countries as a popular and current means of exchange, it wa3 first necessary to find hanks there,which would he willing to purchase them ’freely whenever offered. It i3 unnecessary to say that European hanks operating in these- foreign fields were not over-anxious to see American hankers enter a business which they themselves monopolized up to the beginning of this war. It is only since our own hanks went out into foreign lands and established their own branches that the necessary foreign market for American acceptances has been de veloped. The establishment of foreign branches of American tanks has been a most important step in advance, and without it bur acceptance system could not have progressed as far as it has to day. The advent of these American branches 631 -7- forc'ed the other banks to modify their resist ance and to compete for our bills wnich, up to that time, they had tried tc disregard. It is to be hoped that other American banks vail soon follow in establishing themselves in foreign countries. As you knew, the Federal Reserve Board has recommended an amendment to the Act to enable national banks, singly or jointly, to hold stock in banka organized "princi pally to do business in foreign countries. " Ohe U 11 has already passed the House, and . another has been reported favorably by the Sen ate committee on banking and currency. The Board hopes that a satisfactory bill will be agreed upon by both houses in the very near future. It is a strange fact,however, that many of our business men, who enjoy the reputation of being keen and progressive, are actually wasting their funds by still using foreign ac- ceptance credits instead of- American. At Rio, I found tc my surprise that the majority of American coffee importers were still using let ters of credit in sterling for which they were paying a discount rats of about. as against the American discount rate of 2f>. Moreover, in doing so, they were often paying two commissions, one tc the foreign hanker- who issuesjand one to the American hanker who opens the credit, in stead of paying a single'commission to the Amer ican hanker. It is true that the wool and hide busi ness, done by New England with the Argentine, is today .financed by dollar acceptances drawn on Bos. ton and New York, and that the oriental trade has begun to use dollar bills, but it is surprising that so large a number of New York importers are still clinging to their old pound sterling acceptance arrangements. 1278 631. - 9 Let me venture to urge most earnestly that our bankers canvass xheir lists of importing and ex porting firms and point out to them tne folly of not using American banking facilities. Since my re turn I have tried to see personally some of these large importing firms and explain to them tho anomaly of their action. I believe,, however, than an asso ciation like yours is particularly wall adapted for carrying on a campaign of education of this kind, With our increasing financial strength and with the daily diminution of Europe's saving power, it stands to reason that, for a long time to come, our discount rates will compare favorably with those of Europe. We may expect, therefore, that this acceptance business will not only hold its own, but will grow and may be used to a substantial extent even by European importers and exporters, and thus relieve Europe of some of her financial burdens. * 631 10 - While our foreign competitors, with few noteworthy exceptions, are still trying to keep cur dollar acceptances in obscurity, our machinery is now firmly organized• There are now local banks almost everywhere abroad willing to buy American drafts going forward for acceptance and to deal in dollar exchange on practically the same narrow margin which prevails in dealings in sterling, marksJor francs, and the Federal Reserve Banks are willing, whenever desired, to do their share by quoting favorable "forward discount rates" to assure the rate of discount pending the time of transit. This new feature of American banking, which is to be one of the roots of our strength and, at the same time, a new source of profitable and sound banking, ought to be developed energetically by both our bankers and cur business men. 79 681 In this connection, it may not he amiss to give you a short account of the conference of the International High Commission at Buenos Aires. In our deliterations, the question of "bank ing was given particular attention, and I am happy to report that the general tendency at the con ference was to do everything possible to foster trade relations between the United States and her neighbors to the South, and mutually to open the doors ’.vide to one another's banks. Resolu- ions w0 2T8 psijsed making for the adoption by Central and South America of uniform laws concern ing bills- of exchange, bills of lading, warehouse receipts, and similar matters. A further recom mendation was adopted by the conference urging the respective governments to enact legislation giving the widest possible protection to the sellers of goods. You. are all lard Hat* with the agreements for the arbitration of business disputes made be tween the United States Chamber of Commerce and the Chamber of Commerce of Buenos Aires* We may expect that other countries will follow in the very near future, and the creation of these agree ments will be an important factor in obviating the annoyance and delay of protracted litigation in foreign countries and in providing for both sides a safe and satisfactory basis for commerce and trade» It would lead too far to enumerate all the topics discussed by the conference. I should not omit, however, to mention that a resolution was passed recommending that all the republics of North,Central;and South America adopt a uni form standard of money of account on the basis of a gold coin 9/l0 fine and weighing 0*33^37 gramme. Thi3 unit, which might be called the Pan American Franc, though nearly the value of the European franc, is not iid &xa&4 equal, Tout is precisely one-fifth of the United States gold dollar. Delegates to the conference had suggest ed making the gold dollar of the United States the unit for all American countries, but against this it was pointed out that the dollar would be too large a denomination for many of the Southern republics, where small coins circulate and vhere, it was feared, the larger unit of money of-account would bring about an increased cost of living. Moreover, the United States gold dollar could not be divided into subsidiary coins small enough to comply with the known de mands of many of these countries. It was thought, therefore, that a unit of the approx imate size of the franc would be better adapted to the needs of these countries, but, by adopt ing as the standard unit the exact one-fifth of \2HP, the United States dollar,, the foundation will have been laid for a Pan American union of coins which, sooner or later, may become of great importance- If this plan should be car ried into actual effect, the Pan American 20 Franc piece could ultimately circulate with us as a $4 gold piece and our $5 gold piece could circulate as a 25 Franc piece in South or Cen tral American countries. A unity of standards of this kind will, of course, have great advan tages in facilitating trade between nations. Amongst republics having actually introduced a gold currency on this basis it might ultimately lead to an ■understanding for the establishment of international gold trust or clearing funds, having for their object the elimination of the costs and risks caused by our present wasteful method of shipping and remelting gold coins. plan on these broad lines, submitted by the 1 A Americen delegates, was recommended by the con ference for closer study to all governments con cerned. The immediate practical importance of this step may not be great. As indicative of the trend of future relations between North and South American republics, however, it can not be over estimated. It shows, as one of the effects of the war and of our financial emancipation, that the North and South have recognized their common economic and political interests; that they have begun to consider this large hemisphere as one economic unit, and that they are now looking to each other for mutual help and cooperation in the future development of their respective prob lems. A Pan American monetary union, therefore, now appears a more natural basis for the future monetary systems of American republics than a >3 Latin union based upon an agreement with France, Italy, Swtizerland and Belgium. Our friends in South American consider the creation of our Federal. Reserve System as one of our greatest achievements, and their willing ness to rely upon our ability to provide - to a certain extent at least - such financial aid as Europe gave them in the past is predicated upon the confidence that our new system inspires . Some of these republics are carefully studying .this system .with a view to establishing, at the proper.time a similar -banking machinery. In view of the fact that several of these coun tries are federations like the United States and cover tremendous areas of territory, it is evident that certain features of our system would be particularly well adapted to their needs. 85 681 -1 7 - Tfthile observing financial and commercial conditions in these countries, it was deeply im pressed upon my mind how much the United States* by legislative action, had in the past, handi capped the development of .our business in foreign lands. It would lead too far to mention to what extent our own legislation in the past has driven our merchant marine from the ocean and how far it has handicapped our industries by not permitting reasonable trade combinations enabling us to com pete in foreign markets. But it is well within the bounds of this address to mention that the British, French and German banks for generations have been entirely free to go into foreign coun tries to open branches or acquire foreign banks and to do everything and anything to further their banking and trade. On the other hand, our na- si 681. - n a tional banks, until the passage of the Federal Reserve Act, were forbidden by lew to enter these fields or to accept drafts for importations or exportations or to exercise many other functions necessary to develop foreign tanking and foreign commerce. It is a relief to feel that at least the time has come when a clear recognition of our country's banking needs is asserting itself and when most of these old shackles have been removed. Whatever obstacle remains we may con fidently hope to see gradually eliminated. Some amendments along these lines are at present under consideration by Congress, and have already been favorably reported. The Board has recommended that Congress permit member banks to give their acceptances not only for the financing of transactions involving importations and exportations, but also, <ru to a limited, degree and under the supervision of the Federal Reserve Board, for bankers’ clean three months’ drafts, such as are required in foreign countries for remittances abroad. As most of you know, in South America, such remit tances to foreign lands are generally not made by checks but by three months’ drafts, and it is necessary that national banks be permitted to accept for this kind of foreign exchange trans actions:, if the dollar bill is to be used as freely in foreign lands as is the sterling, the franc, and the mark exchange. Turning to amendments touching domestic operations, we have recommended that national banks be permitted to accept drafts or bills growing out of transactions involving the do mestic shipment of goods, provided shipping doc uments are attached at the time of acceptance, ■f!OfiQ and drafts and bills 'which arc secured by ware house or similar receipts covering readily mar ketable staples,or by the pledge of goods actual ly sold. We feel confident that, by enlarging the powers of national banks to accept in this manner we shall open for our member banks a new and profitable field of operation, and incident ally the free development of this kind of bank ers’ domestic acceptance will be an important, factor in equalizing interest rates in the var ious parts of the country and will be of great benefit in this respect alike to producer and consumer. We have also proposed an amendment authorizing any national bank, located in a city of more than 100,000 inhabitants and possessing a capital and surplus of $1,000,000 or mere, to establish branches within the corporate limits of its city, and authorizing any national bank -ff o ? - ;-,„rsse> j 681 - 21- located in any other place, with the approval of the Federal Reserve Board, to ectablish branches within the limits of its county cr within a radius of 25 miles of its hanking house, irrespective of county lines. In recommending the county line for branches, the Board was moved by the thought that it might be found convenient for several small hanks doing busi ness in the same county to combine into one larger hank, thereby reducing the overhead char ges and making the deposits of one part of the county available for the demands in another. It is the hope of the Board that in some districts, through such cooperation, it will he possible to reduce the exorbitant interest rates which, in some instances, have been charged by small country banks. The Senate committee ha3 stipula- • ted that, for the beginning at least, the num ber of branches of a national bank shall be re- 90 ..f, r % 681 - 23- stricted to ten. We have further recommended to Congress that any national "bank, not situated in a central reserve city, be permitted, within the same limits now existing for loans on farm lands, to make advances maturing in not ever one year on improved real estate located anywhere within a radius of one hundred miles of its place of business. Wnile the Board doe:; not favor the idea of having na tional banks make heavy investments in mortgages, it was felt that they should not be precluded from taking, within certain reasonable limits, first mortgages as collateral security for their loans. These are the additional powers that we have recommended to be given to national banks. As to the Federal Reserve Banks, we have suggested that Congress permit them to make advances to their member banks on the latters1 own 91 ,<v 681. - 23 notes secured by eligible paper, such loans to be for periods not exceeding fifteen days. This has been done with a view to enabling Federal Re serve Banks to accommodate members who, in the check clearing or otherwise, might bo short in their balances and wish to have short advances at moderate rates. We.believe that this power, if granted to Federal Reserve Banks, will greatly increase their ability to take care, in a simple and effective manner, of the requirements of their members, and particularly of country banks. Vie have further recommended that Congress permit Federal Reserve Banks to issue Federal Reserve notes, not only against commercial paper, but also against the deposit of gold. This amendment, if granted, -would greatly strengthen the lending power and the note issuing power of Federal Reserve Banks. It is the seme method 93 that has always been followed in Europe by the Barque do France, the Reichsbank, the Bank of the Netherlands, the Bank of Italy and many other government banks. These institutions are enabled, through their note issue, to assemble a large part of the gold of the country in a central reservoir. With us, up to the present time, this accumulation of gold has taken place to only a moderate extent and hao not benefittea the Federal Reserve Banks to the fullest possible degree. If the amendment were to be passed, the gold, instead of being segregated with the Federal Reserve Agent, would remain an asset of the Federal Reserve Bank, and, on the other hand, the notes issued against it, instead of being, as at present, technically redeemed, would remain the liability of the Federal Reserve Bank. In case the amendment should pass, it is hoped that the Federal Reserve Banks may count upon the cooperation of their members in order to facili tate this substitution of Federal Reserve notes for gold certificates at' v-h-cent carried in the pockets of the people in the old-fashioned and uneconomic manner. As in modern European count ries, the gold should-accumulate in the FederaltReserve Banks and the people should use instead the Federal Reserve notes. The amendment would be an important step in the ultimate simplification and consolidation of our circulation. These are the principal amendments recom mended by the Board at this time. You will notice, gentlemen, that they move in two directions. The one is an increase of the Reserve Bank’s general strength and lending power and an enlargement of their scope of usefulness in dealing 1295 681 - 26 - with their members; the other i3 the re'mov'p.i of limitations heretofore placed upon the opera ticno of national hanks. The Board feels keenly that, as a matter of equity, national bank* should he placed on a parity with State hanks and trust companies, vdierev^r this can he done consistently with safety and conservative hanking principles. But I wish to make it clear that the Board has recommended, and will recom mend, only -such measures as will eliminate oldfashioned or ur.wi3e restrictions such as should he removed under any circumstances, irrespect ive cf Aether or not the State banks exercise greater or lesser pc./ers. The Board would never recommend granting national hanks any powers .or privileges Tifcich are contrary to good hanking principles. It is to the interest of both State institutions and national hanks that hanking 1296 631 -27- standards should he raised wherever practicable and not that they should he lowered. Between the national and State hanking systems, there must not he any competition to secure more members hy a lowering of banking standards. The vdiole country would suffer if this took place. It would he the height cf folly if States were to lower their requirements for no other reason than to underbid the requirements of national hanks. To a certain degree this has been donewhere State goverments lowered the reserve re quirements for their hanking institutions because the Federal Reserve Act lowered the reserve re quirements for national hanks. The lowering of the reserve requirements for national hanks was prodicat6d,however, upon their joining the Federal Reserve System subscribing to the stock and put ting some part of their reserves into the joint jLi'*i/ ^ 681 - 28- insurance fund,and being bound ultimately to abandon the method of pyramiding reserves and ■ to keep them instead either entirely in metal lic form or with the Federal Reserve Banks. The reserves of State institutions, on the other hand, were lowered without their being t required to join the system, make any such con tribution, or discontinue pyramiding reserves. Moreover, lower reserve requirements are jus tified for member banks because they may have direct recourse to the rediscount facilities of the reserve system, but non-memb6r banks have no such direct access. I wish* I could adequately impress upon the minds of all our bankers that there i3- no such thing as doing anything for the Federal Reserve System. Whatever the member banks do, and .what ever the State banks do> they do for themselves 1298 681 -29- and for the country. The Federal Reserve System, a3 such, i3 nox a 3elf-seeking and profit-making organization. It "belongs to the entire country. It is there for the benefit of everybody for the greater security of the banks, and, through the banko, for the security of the'people. If you strengthen the Federal Reserve System, you strengthen yourselves. If you raise the sxancUard of banking, it is for your own benefit not for xhs benefit of the Federal Reserve Banks, or least> of all, for that of the Federal Reserve Board. These things appear trite,but still I cam not help expressing them because it i3 so absolute ly essential that the thought be overcome that there can be such a thing a3 a conflict of interests between the Federal Reserve System and the banks. The Federal Reserve System and all it means is felt as an opposing factor where it comes into conflict with had hanking practices. It is true that the law has f or one of its ob jects the removal of certain,habits which have crept into the old hanking system, hut it is equally true that, by removing them, financial catastrophes such as used to befall our country with uncanny regularity, are to be avoided in the future. Let us consider, as the strongest case in point, the pyramiding of reserves. I wash it had been possible to stamp out this e-avil within a short time alter the opening of the Federal Re serve System. Is it is, many of the smaller banks are still in the condition of a patient who knows that he must undergo an operation in order to be fully cured, but whose mind every now and then rebels at the thought, and who con tinually relapses into arguing with himself that after all, he might possibly prefer to continue (!> to live with his disease and take his chances of the certain recurrence of acute convulsions and intense suffering rather than to have the operation performed. The country,, however, has decided that the operation is necessary for our future safety and growth, and the vast majority of our hankers are in full accord that it is the wisest thing to do. The pyramiding of reserves will thus end on November 16, 1917. But, as I said, I wish the operation had already been performed. At present our national banks apparently have excess reserves approaching one billion dol lars. Of these, a substantial proportion repre sents items in transit between the depositing and the depository banks; the balance, ex cepting about $100,000,000 excess cash in vault held by all national banks outside of New York, is kept entirely in central reserve cities, the hulk being in the City of New York* There it is on deposit - drawing interest at the rate of 2$ and loaned out on stock exchange and other col lateral, or invested in commercial paper, except as to the required reserve of 18$ and the small total excess reserve of about fifty million dol lars. This is a reduction of excess cash re serves in New York of over $100,000,000 since January 22d. If Farmer Jones deposits $1,003 in a bank of Elk River, Minnesota, and this bank should in turn deposit this amount in a bank at Minneapolis and the Minneapolis bank in turn deposit it in New York at 2$ interest, and New York invest this money in a piece of commercial paper at 3$ in terest, it is a .most extraordinary and unique method to permit Elk River and Minneapolis to If count these deposits as reserves, while if the hank of Elk River had itself bought the piece of p&#er it would havi carried it as a loan and all the rest of the structure of reserve hank depos its and reserves would have been wiped out* In other words, in the final analysis, if we consider the system as a unit, there is not an excess reserve of one billion but only about in cash; $150,000 ,000 './ the balance is invested to-day in the "float", representing uncollected items in transit, commercial paper, stock exchange loans and securities. If we study the changes in the condition of the New York Clearing House nation al banks which have occurred between October Jlj 191^4, and May 1, 1916, we find the following in creases estimated at: *> JmO 03 681 - 34 Oct. 31/14 May 11/16 . Collateral loans.... 5^7 mill- to 95^ - plus U07 Investments in securities.......... 10 o 11 " 230 - . " I7 U Unsecured loans which include com mercial paper..... Uo6 11 n 667 - 261 ,T A total increase of ................ During that period, deposits increased from........... 1200 n « 210 0 - $8^2 " 900 In addition, collateral loans and holdings of securities of New York non-member trust com panies increased by about half a billion since the end of 1 9 1 U. These are phenomenal increases and we might well ask ourselves whether or not we may take it as a certainty that so extraordinary a growth will prove to have come to stay or whether a return of more nearly normal conditions will not bring about a contraction. We should well con sider this question, because'an increase of 90 $ f> in securities and collateral loans; - that is, an increase of over $1,000,000,000 in New York City Clearing House institutions - might well suggest a policy of liquidation rather than one of fur ther expansion. Our national tank cash reserves in central reserve cities (including balances with Federal Reserve Banks, figured at 100$) were as of March 7, 22*83$; in reserve cities, 11.53$, 'and in country banks 9.80$ *. Notwith standing that the aggregate cash held by all national banks increased from May, 1915, to March, 1916, by over $100,000,000; in central reserve cities we are today materially below the * If we figured these balances at 70$, being the present cash reserve condition, and the act ual' metallic reserve, and added to cash in vault the metallic cover maintained against reserve agents’ balances, the present cash cover would show as follows: central reserve, 20.51$; re serve cities 13.66$ and country banks 11.83$. 04 old cash reserve requirements, and if a situa tion like the present had existed during any ante-Federal Reserve System period, we should have considered it a cause for alarm. Thanks to the creation of our new banking system, we are now dealing with completely changed condi tions, and the spectre of the end of the lend ing power of the banks would not mean a panic as in the past because of the reserve lending power of the Federal Reserve Banks and the confidence created by their existence. But, gentlemen, that must not lead us into the illusion that this billion of so-called excess reserves may be considered as a basis for a loan expansion of four billion dollars or more, as appears to be the general belief. Theoretically there is the foundation for so large an expansion as long as we adhere to the old custom of counting 681. 37 - bank balances with reserve agdhts and uncollected iteira in transit as reserve, yet, in the last analysis, it is the metallic cover - not the redeposited and actually invested reserves - which must be considered in dealing with this question of expansion of loans. The excess of our metallic reserve, plus the free gold of the Federal Reserve banks, constitute the basis of the reserve lending power of our country. We are at present in a condition of extra ordinary strength. We have bought back our own securities and made foreign loans to an aggregate amount far in excess of $2,000,000,'000. Our financial position for the future has thus been greatly fortified. But the process of absorption of our securities returning from abroad should be conducted on such turn the individual basis and scope as to depositor into an invest- 681 -38- or so as to free our gold reserves rather than increase our loans on an enla,rged floating sup ply of securities. We must not forget for a moment that not even the most experienced can foretell what de mands may be made upon us in the future. At the end of the war our opportunities will be gigantic, but ultimately they will be limited by the extent 'to which we are able to control our gold. There cannot be an]/- doubt that the demand for gold at that time will be very keen and determined. Wise statesmanship, to my mind, therefore, would indicate that every thing should be done by the Federal Reserve System and by ail the banks that are interest ed in our strength to watch carefully further expansion at this time and to accumulate the floating gold supply in the hands of the Fed- eral reserve banks so as to enable 'them* when the time domes, if necessary, to spare large amounts without thereby crippling their lending power. We are in a period of wide-spread pros perity at this time and it must be our serious concern not to weaken its solid foundation* The ease of this summer might well be used to strengthen and prepare ourselves for the large problems that may be in store for us. It is impossible to try to prognosticate with any degree of certainty what will t>e the trend-of interest rates at the end of the war, but assuming that interest rates for invest ments in Europe will ebe high, and that the de mand for gold on the part of Europe will be keen, we would have to expect as a consequence that eventually our rates will have to move up so as to approach theirs mors closely, and be fore we reach that point probably a substantial amount of our gold will have to leave the country and return to foreign lands. To preserve the advantage of our strength and to maintain our money rates on an independent basis of cur own in spite of the close inter— relation that must exist between us and Europe - will be one of our interesting but difficult tasks. The establishment of the Federal Reserve System has been a step of inestimable value in the direction of efficient control of our country’s gold holdings; and, if we do not disregard all rules of business conservatism and prudence, it will prove an efficient means of protection in case of emergencies. If we want more than a strong instru ment of defense and protection, if we desire - as we are entitled to - that the Federal Reserve System be the foundation of a banking structure 581. 41 - contributing its full share in rebuilding the World and at the same tune assisting our own country to meet all the new demands, -whether domestic or foreign, that the future may make upon it, then we must do all we can to preserve its strength and to broaden its foundation by further perfecting methods of systematically accumulating and economically using our vast treasure of gold* loo large a proj>6rtion of this gold still remaihs wastefulljr fedaiteredl and decentralized. The gold stock of this country is es timated at $2,320,00C,000. Of this amount, only $335,000,000 is held in the vaults of the Federal Reserve Banks and about $180,000,000 is in the hands of the Federal Reserve Agents. The national banks and State institutions hold about $800,000,000, and there is estimated to be in actual 681. - .1+2 - circulation about $870,000,000. If we abduct from the $335,000,000 held by all federal Re serve Banks a minimum reserve of only 40%,' that would leave as their fi~ee gold about $200,000,000. This is an invaluable item of strength as a basis for a note issue of $500,000,000 in case additional currency should be demanded by our people; and the Board, by permitting the reduction of the 40% gold reserve, could, in case of emergency, sanction the issue of even larger amounts. When, however, it comes to ex portations of gold you can readily see that the $180,000,000 now accumulated with the Federal Reserve Agents would serve as a very welcome additional protection. For we have learned, gentlemen, that this is a period of economic history, ’ where balances between nations are not dealt with in millions, but in hundreds of millions 1313 681. - 43 - Think of the strength that our system might possess if we carried into effect the policies pursued by the Banque de France., the Reichsbank or other powerful central banks, and if, for a substantial part of the $870,000,000 of actual gold circulation, there were substituted our Federal Reserve notes, and if national and State banks kept in their vaults only what they needed for till money and deposited with the Federal Reserve Banks the rest of their idle gold. We talk of preparedness as the need of the hour. If we contemplate what European nationa have done, before and during the war, to streng then their grip on their gol^ and compare it with our own efforts, ws find that our financial preparedness is just in its first stages. The amendment recommended by the Board should prove an important step in advance in this direction 1313 681 a - 43-x - In view of the statement made by some, of Our critics that this substitution of Federal Re serve notes for gold certificates means inflation, it might be timely to point out that, by a simple substitution of one note for the other, there is, of course, no increase in the volume of circula tion whatsoever. It is merely a change in the form of circulation. As a matter of fact, we find that the operation of all Federal Reserve Banks for a period of one and a half years has caused a net increase in the circulating medium of the country, serve notes and by the issue of Federal Re Federal Reserve Bank notes, of less than $10,000,000* On the other hand, the national bank circulation has decreased during the period Hovember 2, 1914, to June 1, 1916, by $53,000,000, exclusive of the redemp tion of the approximately $385,000,000 of emergency currency issued under the so-called 1314 Aldrich-Vreeland Act, While it is evident., therefore, tha/t the Federal Reserve System has not increased the volume of circulation, the process of substituting, as a moans of circulation, the Federal Reserve note for the gold certificate has the most important effect of strengthening the potential lending and note issuing power of Federal Reserve Banks in case of need. To refuse this larger power of pro tection for fear that it might be misused would be rantamoum to refusing to give a modern revolver to a policeman for fear that he might shoot at the wrong man and at the wrong time. 1315 681 < - 44 - But, let me ask you, gentlemen, is this the proper time for country bankers to urge us to recommend to Congress the further reduction of their reserve requirements or to recommend that they be granted permission to continue to hold a certain percentage of their reserves with their central or reserve city correspondents'? Some day, no doubt, it will be proper to reduce reserve requirements, but that can only be brought about by a systematic strengthening of the central reservoirs. The stronger the Federal Reserve. Banks, the easier the access to their resoui'ces by sale of liquid paper, the less will become the necessity fcr member banks to maintain in their own vaults, as a legal requirement, large segregated gold hold ings . 1316 681. - 45 - Steps in this direction are: first,'the substitution of Federal Reserve notes for the gold circulation in the pockets of the people; second, the maintenance with Federal Reserve Banks of larger member banks? balances, created by depositing part of the “optional” now kept in vault by member banks, and, finally, the increase of the number of depositors to be secured through the entrance of the State institutions into our system. I want to compliment our large member trust companies and State banks upon the broad point of view which guided them when entering the system; but I might at the same time ask their powerful sister institutions how, under present conditions, they can justify themselves in staying out of the system and in throwing the entire responsibility and burden upon the shoulders of the national banks 1317 681. _ 46 - and those few trust companies and State tanks that have hecome members? They do not contribute their fair share of gold to the general reserve fund of the nation, nor do they provide their share of the capital cf the Federal Reserve Banks. Indeed, not only do they fail to contribute their share of strength to the system, but unconsciously per haps, they become forces that make for the direct weakening of its strength and efficiency. Do the large trust companies and State banks claim that pyramiding of reserves is sound? Would they prefer to see our ancient system per petuated and the reforms contemplated by the Fed eral Reserve Act abandoned so as to make room again for the good old conditions of 1893 and 1907? Unless they are willing to subscribe to that doc- 1318 trine, how can these large hanking institutions, some located in Central Reserve cities, justify themselves in considering as reserve, after the manner of the country banks, their interest bear ing deposits with other banks? If a call loan on the stock exchangemade by a trust company is not a reserve but a loan, is it sound banking to call a reserve deposit made by a trust company in a national bank a re serve, when 82$ of it is loan on call on the stock exchange? Still, it is just through these deposits that, in emergencies, the trust companies will lean on the national banks and the national banks, in turn, will fall back on the Federal Reserve System* The net result is that the trust companies, in building up their business structure, must rely today on the greater assurance provided by the Federal ±319 Reserve System, though permitting the member banks to carry the entire burden of its support. Our small country banks will have to stop pyr amiding of reserves; do the large trust companies and State banks plan to continue this practice? What is it that powerful and prominent institutions,(some of which, in their foreign and acceptance business, derive the greatest pos sible advantage from the discount market and the general prestige of the Federal Reserve System,) may say in justification of such an attitude? At first they feared that, by entering the system they might lose some of their present powers and privileges. But the Board has made regulations permitting them to continue to ex ercise practically all legitimate banking func tions enjoyed by them in the past. 681., - 49 - Some of the State institutions have raised the point that, by joining the Federal Reserve System, they would be called upon to make invest ments in the stock of the Federal Reserve Banks upon which, in the case of most of the Federal Reserve Banks, no return has as yet been paid. But, gentlemen, while for many reasons some of us would favor an amendment permitting a Federal Reserve Bank to pay back a portion of the capital paid in (leaving the liability upon the subscribed but unpaid capital otherwise un changed) provided the member would in turn agree to increase its required reserve balance by a certain proportion of its optional balance, this question in itself can not possibly be of sufficient im portance to keep any strong State institution out of the system. These dividends are 1321 681. - 50 - cumulative, and anybody having a moderate de gree of foresight can readily approciate that, sooner or later, the back dividends will all be paid. of Even at the present low rate of return 2 .4 /3, secured by Federal Reserve Banks from their investments, they would have to employ only an additional sum of less than $50,000,000 for the entire system to earn the full six per cent on the stock at present paid in. When the final instalment of reserves has been trans ferred and with the return of more nearly . normal rates of interest, there will not be the least difficulty for these banks to earn their dividends without investing a larger proportion of their resources than would be consistent with safety ana conservatism. State banks and trust companies furthermore 681. - 51 - claimed that if they entered they could not withdraw. But the Board in the exercise of its power to prescribe regulations as a con dition of membership,, has provided that they may withdraw under conditions previously made known,and the subscription to the stock of a Federal Reserve Bank made by a State institu tion is conditioned upon this express agree ment . They have objected to being examined both by their own banking department and by the examiner of the Comptroller of the Currency. The Board, in accordance with the provisions of the Federal Reserve Act, has provided, how ever, that, wherever there is an efficient State examination, as in New York, it shall be accepted in place of examination by the 681 - 52 Comptroller and, only failing that,, an examihation shall he made by examiners under the supervision of the Federal Reserve Board# Furthermore., in a circular letter sent to all State member banks in May of this ye£th, the Board and the Comptroller of the Currency announced that State member banks in making their stated re ports to the Comptroller of the Currency, might use the form of statement prescribed by their respective State banking departments, provided they are rend ered as of the same date as required by the Comp troller of the Currency for national banks* If reports are not rendered on those dates, State mem ber banks are required to use the same forms as na tional banks, but they may omit from their reports to the Comptroller all schedules except that relat ing to coin or coin certificates. They have feared that the Clayton Act would deprive them of valuable directors* But Congress has amended that Act so as to permit a director of a member bank to be* at the same a ' time,/.director of two other banks or trust com panies, provided they are not insubstantial competition “with the member bank. I know the arguments tha~ are being advanced that the rulings c l the Board may be changed and that, therefore, it may be possible, under a different personnel of the Board,to re verse the present arrangement and subject tho State banks tc the examinations.* reports, and rulings of the Comptroller of the Currency* But that is not likely to happen, and if it did, the State bank or trust company could exercise its privilege to withdraw from membership' in the system. Let us assume,however,that joining the 1325 581 ~2-A- Federal Reserve System does involve certain sacrifices,, some of which are necessary-and some of uhich may be thought unnecessary*. If you throw into one side of the scales all thar benefits accruing tc the bank3 and the nation by the creation of the Federal Reserve System J and into the other the sacrifices to be mads by its members, there can not be any doubt what soever that the advantages will outweigh the disadvantages a thousandfold* The Federal Reserve Act is one of the most constructive pieces of legislation that ever was put upon our statute books* Nobody could be foolish enough to expect that a lav/ which is so complicated in its nature, so far-reaching in its scope, and a ccmprimise in so many details between opposing views, could be absolutely perfect* It is a wonder that, frcm the beginning, it has proved as workable as. it 1326 681 ^■3-rA- has* Personally* I am on record as having posed several of its features of detail* But, when the President honored me "by inviting me to become a member of the Boards I accepted be cause I felt that the fundamental principles were sound and that the Act, as it stood, would redound to the greatest benefit of the country. I felt confident that if after sincere and un biased efforts in the operation pf the Reserve banks, defects should develop that needed cor rection, we could confidently count on a pa tient and sympathetic hearing before Congress* And let me remind you, gentlemen, that several of my colleagues and the able men vho accepted to serve at the head of your Federal Reserve Bank .of JTew York, all ,j cined in the same spirit; they did so for th6 purpose of serving their ap 1327 681. - 4-A - country oven though, they had to make material sacrifices in doing so. In one of his admirable speeches., entitled "Ideals and Doubts", Oliver Wendell Holmes, As sociate Justice of the Supreme Court of the United States, makes the following statement concerning the. topic of legal reform; "To know what you want and why you think that such a measure will help it is the first but by no means the last step towards intelligent legal reform. The other and more diffi cult one is to realise what you must give up to get it, and to consider whether you are ready to pay the price." These £,re golden words of wisdom which, at the present juncture of our economic history, every bank president in the United States ought to have constantly before his eyes. For generations we have lived shackled and constantly menaced by a defective and oldfashioned banking system; for years we have toiled to secure reform. We have at last brought it about and, whether or not it pleases everybody in every detail, it behooves us all to do our share in making it a success for the greatest pos sible benefit of our country, no matter whether it involves some small or even a heavy sacrifice. That is the principle which members of the Board have laid down for themselves, and if they are to be faithful to their trust and successful in their task, there is no other principle upon which they can deal with the banks of the country. That is why, though sincerely appreciating the hardship it entails for the country banker, and fully sympathizing with the difficulties of his position, we must say to him: "Forget these ex change charges. We think our new clearing plan is fair and equitable, free from unsound principles ■ and bound to become a very effective instrument for the general good. It offers to take from you at par all your checks on any member bank of the entire United 681 - 6-A - States, and certain State banks in addition, and will refund you any actual expense that you may incur in case you have to remit currency. All it asks of you in return is that you remit without 'charge to your Federal Reserve Bank in payment of checks drawn on yourself* But even if we did not believe that, by the service we render and by relieving you of the necessity of maintaining bank balances all over the country, we shall compensate you for what you think will be your loss, we have to hold to the view that you must pay the price - whatever your little share may be - for the larger bene fit of all." The new system brings new opportunities, as an illustration, let me remind the country banker that his exchange lose will appear to him very unimportant if he will adopt, the habit 1330 6SI. - 7-A - of paying for his deposits a fluctuating rate of interest, which should always remain a cer tain percentage heiow the ninety day discount rate of his Federal Reserve Bank- The unrea sonable rates paid for deposit money are a seri ous menace to the safety of our banking system and the economic development of our country. And, with this seme spirit, and even with greater emphasis, we must say to the State banks and trust companies: At this momentous period of its financial history, the country is entitled to have its banking system attain its maximum strength. Ir respective of burdens involved - imaginary or real - it is the duty especially of these large State institutions to come in promptly and con tribute their share, making whatever suggestions they think helpful as friends and members rather than as critics from the outside. I am glad to state that one of our largest trust companies expressed precisely this broad point of view when applying for membership. The Federal Reserve System will grow stronger with every coning day, and the stronger it grows and the more it perfects its organiza tion, the more apparent will its benefits become for all its members, A great deal of pressure has been brough to b®ar upon the Federal Reserve Board, particu larly during the early stages of the development of American bankers1 acceptances, to cause dis crimination against the acceptances of non member banks. So far the Board has been dis inclined to favor such a policy as it was thought to be in the general interest of the country to give encouragement to the freest and fullest development of this acceptance business, which is of the greatest benefit to the trade of our country. The Board thought further that time should be given to the State banks and trust companies to acquaint themselves fully with the policies tc- be pursued both in dealing with State institutions in general and the accept ance business in particular. Nor does the collection plan just approved by the Federal Reserve Board contain any element of discrimi nation against non-member State banks collect ing, at par //.ithout cost, their out of town checks through member banks of the system. The Board believes, however, that the time has now come for these large institutions to recog nize their duty to join the system. It will not be long before the banks that stay out of the system will become conscious of the fact that member banks will command the greater 1333 681. 10-4 - confidence, and there is nc doubt that the pub lic will begin to resent having its interests sacrificed for the benefit of institutions un willing to join the general protective system, and that before long their resentment will have to be heeded. Before ©losing, I should like to make it clear that, though speaking to the New York State Bankers* Association, whatever I have said is meant to apply to the State institutions of the entire country. I should not wish to give the impression that I am particularly critical of the New York institutions. Quite the contrary, I am very glad to have this opportunity of tes tifying publicly to the spirit of good citizenship that you have manifested in every phase of the development of the system from the very first 1334 v beginnings - when we were dealing with the gold and cotton funds in the fall of 1914,, In the negotiations, resulting in the creation of these two funds, there assorted itself for the first tin® in our financial history a bread national spirit uniting in a work of patriotic cooperation national banks, State banks and trust companies of every section of the country. That was the first effect of the coming of the Fed eral Reserve System, . the physical organization of which at that time had not even been completed. Ib is this same spirit, this larger conception of banking functions and ideals, that will ultimately lead into the Federal Reserve System all elements worth hewing - that is, all elements of financial and moral strength. I trust that my frankness will not be misunderstood by you. There is an old adage that "imitation is the sincerest form of flattery." 1335 I venture to paraphase this saying iniot "frankness is the sincerest form of flattery, ■because it shows that you respect the intelli gence and moral fibre of your audience. I believe that our future looms large beyond measure; I believe it our duty to be financially prepared on the broadest possible scale; I believe that we should use the months ahead of us; not to expand any further, but rather to consolidate our strength; I believe that, through the Federal Re serve Banks, we should strengthen our hold on the gold in circulation ana that the stronger the geld holdings of these banks, the better shall we be equipped to cope with the problems ahead of us, of helping ourselves and of help ing the world; 1336 681. - 13-A - I "believe it to be the duty of every bank in thd country to contribute its share in equipping cur rlktion for this task; I believe that State institutions which are strong enough should cone in now and do their share, no matter whether or not they are in full accord with every detail of the Federal Reserve machinery; I believe that, as we proceed and gain in experience, whatever may prove harmful will be remedied. The tendency of the country is for a fair deal for fair people; While I believe that the country expects that strong State institutions should do their duty and join, we are neither begging nor club bing anybody to come in or to stay in; But I firmly believe that the future will 1337 681. - I4-A belhng to those hanks - national or State that are members of the Federal Resente System. Fini3 1338 682 May 26, 1916. -*** Memorandum for the Board in re interpretation to he given to the language "substantial com petition" as used in the re cent amendment to the Clayton Act. The Clayton Act is entitled BAn Act to supple ment existing laws against unlawful restraints and monop olies, and for other purposes". In so far as it relates to the business of banking it provides in substance that ( Section 8 ) (1) No banking association organized or operat ing under the laws of the United States, and located in a • ^ ( city of more than two hundred thousand inhabitants, shall have as an officer, director, or employee a private banker or an officer, director, or employee of another bank lo cated in the same city. (2) The same person shall not be an officer, director, or employee of two banking associations organized or operating under the laws of the United States if either has deposits, capital, surplus, or undivided profits aggre7 gating more than five million dollars. (3 ) That no banking association organized and operating under the laws of the United States shall have as a director a private banker or a director of a state bank 682 -2- or trust company v\hich has deposits, capital, surplus and undivided profits aggregating more than five million dol lars . There are certain exceptions contained in the original Act to the foregoing restrictions which, for the purposes of this note, it is not now necessary to consider. Considering the general purposes of the Act it may he reasonably assumed that Congress intended to pre vent the same person from ^exercising control over two or more banking associations by serving as an officer, di rector, or employee of both associations where the exer cise of such control would have a tendency to destroy or ♦restrain competition between such banks and thus to create a monopoly. Having constitutional authority to legislate on the subject of banks ''organised or operating under the laws of the United States", Congress undertook to accom plish this object by prescribing qualifications of offi cers, directors, and employees of such banks* It was evidently due to this fact that the particular language used in Section 8 was adopted and in considering the pur pose and intent of Congress this fact should be borne in mind 682 -> While the purpose of the Act, as its title im plies and as the context shows, was to prevent unlawful restraints and monopolies, the particular language used in Section 8, if construed literally, would prevent the same person from being an officer, director, or employee of two different banks under certain circumstances wheth er or not such banks were in competition* The effect of the amendment of May 15* 19 l6 ,is to restore this element of competition as a factor in de termining under what circumstances the same person may serve as an officer, director, or employee of two banking associations. To illustrate, under the Act as passed the same person could not serve as a director of two national banks in the same city of two hundred thousand inhabitants even though such banks were in no sense competitors. Un der the amendment of May 15* 1916, however, the Federal Re serve Board is vested in a discretion to determine first whether such banks are in substantial competition and, if not, to permit a person to serve as a director of both banks* This amendment provides in terms that - "Fc.thing in this Act: shall prohibit a n y .: officer, director,, or employee of any member bank* or Class C- director of a Federal: reserve bank.,.vh o shall first procure the con.sent of the Federal Reserve Board * ’,* * .*’ from being an officer, director, or employee of. not more than.;two.other banks * * * if such other bank * * * is not in substantial, competition with such-member bank®. " ■ ;■ It' is, therefore, necessary for the Board ’ to determine under what' -circumstances two banking asso ciations located in a city of. more than t w o . h u n d r e d r. -' thousand inhabit aits may be'said to; bs in substantial, ... competition, or when a ^banking association having more .than five' milli-on dollars in .deposits, •capital,- sur-./*. plus/ and. undivided prof it3 may be said to be in .suh- . stantial- competition with another banking-association® It must be assumed that Congress intended thi s ’language, to be- given its usual or ordinary inter pretation® The definition given, by Webster'of the w o r d - " competitibn B and adopted in a.number, of cases, is- - " "The act of seeking or endeavoring to gain what another is endeavoring to gain at •the same time; rivalry; mutual strife for the same object" (State v®. Port. Royal & A.Ry® So/, 23 S. E,, 3 6 3 / 5 6 3 , % 5 Si 0, Ul3, (quot ing Burke v. Big Pour - Ohio.- 22 Wkly. Law. Bull. lU ). .3- 682 -5- In the case of State v« Central Lumber* Co. 121 U. "W*, 50^, the coixrt says •"^Monopoly1 and ’competition* "being the exact opposites, anything tending to de stroy competition tends toward monopoly." The Clayton Act having for its purpose the pre vention of monopolies, it seems clear that it was intend ed, as above suggested, to prevent two banks from having the same officers or directors when such banks are com peting for the same business. The word "substantial" was incorporated in the amendment of May 1 5 , 1916, as a qualification of the word "competition" and its inclusion was in effect a legisla tive sanction of the decisions of several of the courts in cases dealing with this subject. For example, in the case Kimball v. Atchison, T. & S. F. R. CO. ( U. S. ) H6 Fed. 888, 890, the court says - " * * * that when the statute speaks of competing roads it evident-ly means roads that are substantial competitors for business; it refers to competition of some practical im portance, such as is liable to have an appre ciable effect on rates, and in that sense the road to Union was not, in my judgment, a com peting line." 682 - 6 - In.the case of the State v. Central of Georgia R. CO., 15 So E e 17, 18 , 10 q Ga. 7 l6 , U8 L. R. A. 151, the court says : ’ "The question is, at last> one of fact, and in its.adjudication in any particular case the court should be goveriied by the fundamental principle as to whether there was such a creation of a monopoly or de feating of competition as would result in injury to the public. " In the more recent case of the Standard Oil Co. v» United States, 231 U. S» , 1- 6 ^, the court says - "In substance, the propositions urged by the Government are reducible to this : That the language of the statute embraces every contract, combination, etc., in re straint of trade, and hence its text leaves no room for the exercise of judgment, but simply imposes the plain duty of applying its prohibitions to every case within its literal lan guage * * * • The merely generic enumeration which the statute makes of the acts to which it refers and the absence of any definition of restraint of trade as used in the stat ute leaves room for . but one conclusion, which i3, that it was expressly designed not to unduly limit the application of the act by precise definition, but while clearly fixing a standard, that is, by defining the ulterior boundaries which could not be transgressed with impunity, to leave it to be determined by the light of reason,guided by the principles of law and the duty to apply and enforce the public policy embodied in the statute, in every given case whether any particular act or contract was wdthin the contemplation of the statute."See also- Louisville & Nashville Ry. Co. v« Kentucky, l6l U. S„6jj,6^8 Pearsall v. Great Northern Railway, l6l U. S., 6U6,6j6; Dady v. Georgia & A. Ry,, 112 Fed-, 838, 8RU; Rogers v. Nashville, C. '& St. Li Ry. Co., 91 Fed., 299/ 3 ^ / East St. L. Connecting Ry. Co. v/ Jarvis, 93 Fed., 735/ 7^2/ E. L. & Red River Ry.t/o. v. The State, 75 Tex. ^3^/ % 6 . It should be borne in mind that the purpose of the Act is to encourage , or at least to preserve, competi tion between banks. The terms of the Act, however, are not applicable to all national banks but only to banks of a certain size, or banks located in cities of ft Certain size. For example, the director of a national bank in a city of less than two hundred thousand inhabitants may be a director of any num ber of other banks located in cities or towns of less than two hundred thousand inhabitants, provided, none of such banks has deposits , capital, surplus and undivided prof its of more than five million dollars. The theory of the Act appears to have been that all banks in cities of more than two hundred thousand in habitants are presumably competing associations and that every bank with aggregate resources of more than five milmion dollars is presumably a competitor of every other bank regardless of its location. The effect of the amend ment of May 15, 1916, known as the Kern amendment,is that this presumption nay be overcome by,the facts in any given case. On this theory the burden is on the applicant in each case to show by some affirmative evidence that the two banks with which he wishes to be connected are not in sub stantial competition. The Board is, therefore.; confronted with the dif ficulty of determining the kind and character of evidence it wall require to rebut the presumption that the banks in question are active or substantial competitors. Generally speaking it should appear that the two institutions are not seeking the same business- that is to say, they are not seeking to make their earnings from the same sources so that the increase of the business of one should not be expected to have any appreciable ef fect upon the earnings of the other. It is accordingly necessary in each case to consider whether the earnings of one bank are likely to be appreciably affected by an increase of the business of the other. Thi3 necessarily involves a consideration of the source of the earnings of each bank. As a general propo sition a bank’s earnings are derived from those relations which it has with its customers or patrons. The customers may be divided into general classes - ± 682 »cu (1) The depositors, or those who furnish funds to the hank* (2) The borrowers, or those who..pay to the bank in terest or discount for the use of the bank's funds# It is in this respect that the banking business differs from that of corporations engaged in trade or com merce. A manufacturing corporation, for example, derives its profits from the use of its own funds. Such a corpora tion is a competitor of others in the matter of the sale of its products# A bank, however, competes first in procuring funds or deposits and also in the investment of funds so procured. To increase its earnings to any great extent it must increase its deposits. The Board must, therefore, determine first whether the two banks are seeking the same class of depos itors in order to increase their loanable funds, and, sec ondly, whether they are making the same class of loans or investments# In either case the two banks may be competi tors but it is the degree of competition that must be determined. If one bank receives only deposits sub]ect to check and makes short-term commercial loans and discounts 8 4 8 .1347 1 while the other receives only time deposits or savings ac-counts and does not make commercial loans, the case would seem to he free from difficulties. Where both banks re-, ceive checking accounts but one makes commercial loans while the other does not, the question of competition is involved but the fadt that both receive the same class of deposits is by ho ttSahs a cohclusive test* This question Can hot be determined solely by the character of deposits received or the character of the loahs rhade. It is ehtire*. ly conceivable that both banks may engage in a strictly commercial banking business and yet may not be substantial competitors. ■where the bankgare located in different cities or comnunitiet the character of denosits and character of loans and rediscounts may be similar and vet the two banks may not be active or substantial competitors, where they are doing business in the same general locality, however, the character of deoo3 its and character of loans and in vestments become of greater importance in determining the degree of competition. • In a city of two hundred thousand inhabitants the Board might conclude that taking into consideration . 6 8 2 1 8 - -li the-amount of commercial business in that city every bank engaged in a purely commercial banking business is in sub stantial competition with every other bank engaged in the same character of business. On the ether hand, in a city of two million in habitants the commercial business may be of such vol ume that the question of the ddegree of competition will de pend upon the location of the banks in the dity. Banks in the wholesale district may not come into competition to any appreciable extent with bahks in the retail district. It is manifest that each case ifiUst be deter mined upon the facts submitted and that .no fixed rule can be prescribed by the Board to govern all cases. In order to assist the Federal Reserve Agents in making recommendations, however, the following factors should >e called to their attention. J First : As the hanks organized and operating under the lam's of the United States are engaged primarily in the commercial banking business, and as such bank is auth orized by its charter to do a banking business in a. particular citv, town, or village, consideration should be given to volume of commercial business engaged in by bank customers in the -nlace in which the hanks are located. the 1 8 -f 682 -12- SeopiiA: If the two banks ate doing business in the same general locality special consideration should be given (1 ) to the character of deposits received as indicated (a) (b) (c) (d) by the amount of deposits subject to check* by the stmbunt and terms of time deposits and savings accounts; interest paid ; conditions of deposit - that is to say* whether an average bal ance is required; (2 ) to the character of loans and investmentsmade as indicated by^ (a) (b) (c) Third: amount.of short term loans and discounts; investments in real estate; investments in stocks* bonds* and other long time securities. The capital and total resources of the two banks may be considered as a factor. The large bank may make loans of a size that could not be made by a bank of smaller capitalization and for this reason they may serve the same communities without coming into competition to any substantial extent. After considering these several factors and after determining whether the two banks are actual competitors *?/t19 4 «* 682 -l> the Board must still determine whether the extent of this competition brings them within the prohibition of the statute. To do this, it is necessary to determine what form of evil Congress intended to correct. Was it the purpose of Congress to insure to each bank an equal oppor tunity to increase its earnings by preventing the directtors of one bank from controlling the operations of anoth er competitive association, or was this Act intended merely to insure to the public the benefits to be derived from actually competing associations? To illustrate by concrete example, if the same • directors control two competitive banking associations they might give preference in the matter of investments and otherwise to the one in which they have the largest number of shares and may in this way deprive the stock holders of the other from their just proportion of earn ings. On the other hand, viewring the matter from the standpoint of the public, if there are only two bank3 in a given community and both are controlled by the same directors preference may be shown to certain customers in the matter of loans made, interest charged, etc., which would not be shown if the two banks were active competitors for the same business. 1351 682 -1 ^ - Under the common law contracts in restraint of trade were void as a matter of public policy and the so-called anti-trust laws which were amended and supple mented by the Clayton Act are in a sense a% development of the common law rule against those contracts which de stroy competition or restrain trade. The Board should, therefore, take into consid eration the effect on the public in reaching a conclusion as to whether two banks are in substantial competition. That is to say, it should consider whether any control of one by the other can affect the public in any way, as for example, by resulting in a decrease of interest rates paid to depositors or an increase in interest rates charged on loans. It should consider in each case whether the con trol of the bank by the officers of another can affect the earnings of either bank, or the business of either in its relation to the public. As stated, the burden is on the applicant to show by affirmative evidence that the banks are not in substantial competition. Respectfully, M. C. ELLIOTT, Counsel. 6/6/16 W . P. G. HARDING. GOVERNOR PAUL M. WARBURG. VICE GOVERNOR FREDERIC A. DELANO ADOLPH C. M ILLER CHARLES S. HAMLIN Ex -O ffic io Mem bers W ILLIAM G. MCADOC SECRETARY OF THE TREASURY Ch a ir m a n JOHN SKELTON W ILLIAM S COMPTROLLER OF THE CURRENCY FEDERAL RESERVE BOARD WASHINGTON *688 H .P A R K E R SECRETARY SHERMAN P. ALLE N . ASST. SECRETARY AND FISCAL AGENT ADDRESS R E P L Y TO FEDERAL RESERVE BOARD June 6, 1916. Dear Sir: At the meeting of the Federal Reserve Board on June third., 1916, the question of a re-hearing of the Connecticut bankers was discussed and I am in structed to inform you that, while the Board is will ing to give the Connecticut hankers another hearing in the month of June if they should so desire, the Board prefers to postpone such hearing add definite action until after the summer months. A new clearing plan is about to be put into operation and the Board has been assured by those in charge of the Boston Federal Reserve Bank that every effort will be made, by making special arrangements between Boston and New York, to satisfy the conveni ence of the Connecticut banks * Under the circumstances the Board would pre fer to see the results of operation of the new clearing plan before giving a further hearing, but, as stated above, in case the Connecticut banks should wish to be heard at this time in spite of the information above given, the Board will be pleased to fix the date. Yours truly. Governor. ■3 \ 684. June 6, 1916. MEMORANDUM ON SECTION 8 OF THE CLAYTON ACT. $o All Federal Reserve Agents: The provisions of Section 8 of the Clayton Anti-Trust Act which relate to interlocking hank directorates go into effect on October 15, 1916. As originally enacted by Congress, this Section provided in substance (a) That no person shall at the same time be director or other officer or employee of more than one bank or trust com pany organized or operating under the laws of the United States, provided either of such banks or trust companies has resources aggregating more than $5,000,000. The phcaae "organized or operating under the laws of the United States," has been construed to apply not only to national banks, but also to State banks and trust companies which are members of the Federal Reserve System. (b) That no private banker or person who is a director in any State bank or trust company whose resources aggregate more than $5,000,000 shall be eligible to serve at the same time as a director in any bank or banking association organized or op erating tinder the laws of the United States. It will be noted that this particular provision applies only to directors and not to officers and employees. 684. - 2 - (c) That no bank or trust company organized or operating under the laws of the United States located in any city of more than 200,000 inhabitants shall have as a director or other of ficer or employee any private banker or any director or other officer or employee of any other bank or trust company located in the same place. The Act makes certain exceptions to these provisions: (a) They do not apply to mutual savings banks not having a capital stock represented by shares. (b) They do not in any way prohibit a person who is a Class "A" director of a Federal reserve bank from being an of ficer or director or both an officer or director in one member bank. (c) They do not apply to banks or trust companies where the entire capital stock of one is owned by stockholders in the other. On May 15, 1916, Congress passed an amendment to Sec tion 8 of the Clayton Act which is intended to make further exceptions to its restrictions, provided the consent of the Federal Reserve Board is first obtained. This amendment provides that nothing in Section 8 of the Clayton Act shall prohibit any officer, director or employee of any member bank or Class "A" director of a Federal Reserve Bank who shall first procure the .Consent of the Federal Reserve Board from being an officer, di 1355 684 - 3 - director or employee of not more than two other banks, banking associations, or trust companies, whether organised under the laws of the United States or any State, if such other bank, banking association or trust company is not in substantial competition with such member bank. This amendment, which is in the form of a proviso, does not affect or alter the classes of ineligible directors, officers, etc,, as defined by Section 8 before amendment. It merely provides that a person who is an officer or director of a member bank may, with the approval of the Federal Reserve Board, be an officer or director of not more than two other banks or trust companies, whether State or national, in which l1® otherwise would have been ineligible to serve, provided such other banks or trust companies are not in substantial competition with the member bank of which he is andirector or officer. Under the provisions of this amendment it will be necessary for every director, officer, or employee of a member bank to apply for the approval of the Federal Reserve Board to serve as a director, officer, or employee of any other bank or trust company which comes within the inhibitions of Section 8 of the Clayton Act and which is not in substantial competition with his own bank. In this connection it may be mentioned that if a director of a member bank desires to serve as a director of two State banks or trust companies which are not members of the Federal Reserve System, the sole test is whether such other State banks or trust companies are in competition with the member bank and it is inmaterial whether they are in competition with each other. The Federal Reserve Board, before passing upon these applications, will in each case call upon the Federal reserve agents for a report. It will, therefore, be necessary to lay down for the Federal reserve agents certain broad lines that will be observed in dealing with these applications. The most important task will be to define what the Board will consider "substantial competition". Perhaps it may be the easiest way of approach to con sider and decide first what shall not constitute "substantial com petition". Answering this question, it should be said that the mere fact that two banks ("bank" hereinafter will include national banks trust companies or State banks) are in the same locality or of similar size, or that they both belong to the same class of "banks" or that they both are buying commercial paper or securities, or take deposits, or are doing a trust company business, does not constitute "substantial competition". If the mere fact that two banks are taking deposits or are buying commercial paper or bonds should be considered to be "substantial competition", it would be 57 684 - 5 - paramount to excluding directors, officers or employees (herein after called "directors") from serving on any other "hank", because they all would be in "substantial competition". The question is, then, not on the broad character of the functions exercised by these banks, but the determining point of criticism must be the extent and manner in which these functions are exercised. Two men in the United States each wanting a glass of water can not be s&id to be competing with each other where they are standing on the banks of a stream affording sufficient water for all. If, on the other hand, two men in the desert need water, there will indeed be very substantial competition for a single glass of water, the supply being limited to that amount. Two such extreme cases are fairly obvious. The question becomes more difficult of determination, however, as the facts in each case converge from those extremes. Take, for instance, a community supplied by a single reservoir of water. Though there may be an ample amount for all, it is apparent that severe competition or a tendency to monopolize may result from an effort on the part of one to succeed in supplying himself plentifully at the expense of the others, securing thereby a stronger position either for fixing the market price of the water or for arbitrarily discriminating in offering or permitting its enjoyment. In dealing thep,first with the object competed for it is clear that if it is of such broad and general nature and existing in such gehehous supply that it may be considered a general commodity with a wide • market, the mere fact that two banks require such commodity would not make them competing. It would make them competing only if the comnodity which they both desire and can reach were of so restricted a nature that, in trying to acquire it, they would materially affect each other's supply. In other words, where both banks take the same kind of deposits, buy the same kind of paper and securities they must for a substantial portion of their regular business be tapping the same limited or individual field in order to be considered as substantially competi:~. This test should apply irrespective of the location of the two banks in question, though the distance from each other may be an important factor in determining how much each depends upon the same sources of supply. There may be the same class of banks not remote from each other - conceivably in the same city which do not compete because the main business carried on by them may be of an entirely different character. The one may be in the business center, taking business accounts and making business loans and not paying interest on deposits; the other may be an up-town bank, having private accounts, not making business loans and paying interest on deposits of individuals. It is well con ceivable that such two banks may be considered as not in sub stantial competition, even though, for certain investments,they •1359 might have to resort to the same class of investments, but find them in broad market, such as call loans, time loans or commercial paper,, It is possible, on the other hand, that banks of the same class, even though remote from each other, might be doing substantially the same kind of business, and might, therefore, be competing in precisely the same fields and for the same com modities. Such banks are those whose business are so important in scope that they reach into far-distant territories. To illustrate, certain large banks in Chicago and New York, for instance, have ceased to be local institutions. They are banks that have their connections all over the country, that compete with one another in dealing with the deposits of large corpor ations in purchasing their securities, and it is conceivable that such large banks with such ramifications may be considered as competing oven though geographically remote from each other, while two smaller banks in the same cities doing substantially the same character of business would not be held as competing. The degree of such competition must depend upon the facts of each case, and whether the banks in question are "in substantial com petition" must be decided by the Federal Reserve Board after a review of such facts and the recommendations or report of the Federal reserve agent. ty » ft 684. - 8 The Board proposes to adopt the method of advising each Federal reserve hank of the applications made by each di rector. To 'illustrate,, if a Philadelphia director should wish to retain a directorship in New York andj at the same time, one in Chicago, all three Federal reserve agents will be advised of the three directorships involved in the case. They will be re quested particularly to investigate the local concern involved in the application and will all three receive copied of the re ports of their fellow Federal reserve agents, so that they will be in a position to study the entire case before making theih recommendations. The Federal Reserve Board's special committee, after having heard from all Federal reserve agents involved in the application, will make its final recommendation to the Board. 6 / 6 / 16/ 1381 691. LETTER FROM A WORCESTER. MASSACHUSETTS■ NATIONAL BANK. Referring to the Par Collection System which you are to put in operation about July 15th, I have no doubt you are hearing from a great many banks who are against the adoption of this system, but hear very little from the many banks who are in favor of it. Some of the Texas bankers are back of a propoganda to stir up all the banks of the country in opposition to the Par Collection System. The banks in New England, are much in favor of the adoption of this system for the reason that, in New England something similar to this was adopted several years ago by the Boston Clearing House, by which all country banks remit to the Boston Clearing House at par, as you knowi This has been very successful and very satisfactory to the country banks as.well as the city banks. I well remember the opposition of some of the country banks at that time. Their arguments were the same as the Texas bankers are making now, - that they were going to lose the exchange charges which they were making. They did not seem to figure that these items would be made up by their not having to pay exchange on items which were de posited with them on other- banks. In fact, many of them did not re alize that they "were paying exchange, for their city correspondents were taking out several days* time which amounted to the same thing. I trust you will not be deterred by this opposition which, as I understand, comes from the Southwest, and I venture to predict that after it has been in operation for a year, they will all realize that it is a good thing for all. 6/7/1916. CHARLES S . HAMLIN, GOVERNOR FREDERIC A. DELANO, VICE .GOVERNOR PAUL M.WARBURG W. P. G. HARDING ADOLPH C .M IL L ^ I^ ^ Ex -O f f ic io m e m b e r s WILLIAM G. McADOO S ecr etary of th e T r e a su r y CHAIRMAN JOHN SKELTON WILLIAMS FEDERAL RESERVE BOARD Co m p t r o l l e r o f t h e c u r r e n c y H. PARKER WILLIS, SECRETARY SHERMAN P. ALLEN, ASST. SECRETARY A D D R E SS R E P L Y TO WASHINGTON FEDERAL RESERVE BOARD June 9, 1916 . Dear Sir: Inquiry has teen made as to what changes will he neces sary in Form 3 ^ in order to provide for the new general ledger accounts which may have to be opened on July 15 , in connection with the new Clearing Plan. The Board at this time is not prepared to issue de tailed instructions regarding the matter, leaving it to the judg ment of the banks to open such additional general ledger accounts as may be necessary properly to record and report the collection operations of the bank. In order to insure uniform treatment and classification of the items, it is suggested, that in pre paring the Daily Bank Statement (Form 3 ^) and the weekly tele graphic reports, the accounts named below be composed as fol lows : RESOURCES l:Due from Other Federal Reserve Banks", (Code word "BARE") This account should show the gross amount of items forwarded to other Federal reserve banks for collection and credit. "Due from Banks and Bankers", (Code word "BISE") This account should include items sent to • non-member banks for collection and remit tance. "Deferred Debits (Transit Account)", (Code word "BUMP") Items which have been sent to member banks for collection but which have not been charged to the account of member bank on the books of reserve bank. LIABILITIES "Due to other Federal Reserve Banks" (Code word "CHOP") 1363 694. - 2 This account should include the following items: (a) Balance of funds collected, (b) Deferred credits to other Federal reserve banks. Items received upon which credit is deferred. Accounts (a) and (b) to be shown separately in Mail Reports (Form 34) only. "Due to member banks", (Code word "CLAY") Gross amount of balance and items received f'Or credit of member banks. "Deferred Credits - Member banks", (Code word "CORK") Items received but not credited to the account of member bank on the books of the reserve bank. The amount upon which reserve is to be computed will be ascertained in the same manner as at present; namely, subtracting "Total deduction from Gross Deposits" from "Gross Deposits", as shown in Form 34. . For the information of the Division of Statistics, you are respectfully requested to furnish the following: 1. Half a dozen copies of all circulars sent to banks in connection with the collection system which wall be inaugurated July 15« 2* Description of method of recording on books of the re serve banks: (a) Items on member banks; (b) Items on non-member banka collected through member banks* (c) Items on non-member banks sent direct for collection and remittance; (d) Items on member and non-member banks sent to other Federal reserve banks for collection and credit. 3* Information as to additional general ledger accounts which wall be carried to cover clearing operations. 4. Whether daily statements to member banks will show gross balance or net balance. Respectfully, Assistant Secretary PS4 699 Washington, D. C., June l6, 191&* First Draft. A CONSIDERATION OF THE MERITS OF THE QUESTION AS TO WHETHER FEDERAL RESERVE NOTES SHOULD OR SHOULD NOT BE ACCEPTABLE AS RESERVE MONEY. I The Federal Reserve Act provides that Federal Reserve notes should not he accepted as reserves for national banks. Presumably the reason the framers of the Act had for making this restriction may be briefly stated as follows: (l) Federal reserve notes are intended to exist solely as an elastic credit currency which shall expand and contract in volume with the demands of commerce. There is no question whatever about the good ness of Federal reserve notes. (a) They are good because they represent 100 per cent of high-grade commercial paper, endorsed by a member bank; (b) Because there is carried by the issuing bank a reserve against them of at least 40 per cent of gold; (c) They are a first and paramount lien against all the assets of- the issuing bank, which bank is guaranteed by its stockholding members by a provision for double liability upon their stock; (d) The notes are guaranteed by the United States Govern ment; that is, they are an obligation of the Government. Notwithstanding these reasons, the framers of the Act might very properly say that though the notes are amply protected, there should be no confusion of ideas between the goodness of the notes and their availability as reserve; - - *r 699. - 2 (2) The view of those who "believe in authorizing the Reserve Banks to issue a credit currency is that the reserves of the issuing banks must be absolutely above and beyond reproach; that is„ to say, they must be metallic reserves,, either in coin, or the representative of coin, (3 ) The only guarantee against a possible inflation of a credit currency rests upon its redeemability when it is no longer required* II 6n behalf of those opposed to the above views,that is, the opponents of this provision of the Act, and those who believe that it is proper to let Federal Reserve notes be counted as reserves by member banks, the following statements may be made to epitomize the arguments: 1st: They concede the desirability of having the currency elastic; but they say that because Federal Reserve notes have been emitted by &. bank in times of currency demand does not in any way pre vent a contraction of the currency, when the reverse is true, even though the notes emitted remain in circulation. Indeed, it may be argued that the framers of the Act had this very thing in mind. Sup pose, for example, $100,000 of notes are issued for $100,000 worth of three months’ commercial paper: at the expiration of the three months the member banks who endorsedthe paper, and received the credit, pay JL366 699 it off at the Federal Reserve Bank. * There is no certainty, however, that the $100,000 worth of notes put into circulation would thereupon return to the issuing hank simultaneously, and the issuing hank is in different -whether they return or not, provided it has received $100,000 in gold or the equivalent, which it may hold as an offset to its own notes still in circulation; 2nd: The opponents further argue that,- granting all the ar guments of the framers of the Act, they will say that they are con fronted hy a condition and not a theory* conditions are at the present timei Let us consider what these National banks> represented in round figures hy 7600 individual hanks, about one-third of the total number of hanks in the country having deposits equal to about one-half of the total of hank deposits, are permitted at the present time to count as reserves the following: (a) Gold or gold certificates; (h) Silver or silver certificates. (Silver may he considered to he from forty to fifty per cent Government fiat). (c) Greenbacks; (the direct obligation of the Gov ernment, supported by thirty-five per cent of gold; therefore, representing sixty-five per cent fiat). On the other hand. State hanks are permitted very generally to count as reserves Federal Reserve notes and National hank notes. It is therefore argued that if it is proper for National hanks to count as reserve silver and silver certificates, which are from forty to fifty per cent Government fiat, and greenbacks, which are sixty-five per cent Government fiat; or, if it is safe and proper to permit State 1 8 6 699. - U - tanks to count National tank notes, supported wholly ty the direct otligations of the Government (U. S. bonds), it is rather atsurd to say that National tanks shall not te permitted to count as reserve Federal Reserve notes which are not only better supported than any other currency except gold and gold certificates, but are, in addi tion thereto, the direct obligation of the United States Government. 3rd: Viewed from the standpoint, even of credit currency, it is illogical to permit a National tank to count as reserve a credit obtained through the rediscount of commercial paper, entered upon the books of the Federal Reserve Bank as a deposit and as such transfer able anywhere and convertable at the will of the depositing bank into cash or gold, while not permitting them to count as reserve a similar credit taken in the form of Federal Reserve notes; 1+th: If the experience of the last fifty years of American banking means anything, it means that member banks will generally take credits from their rediscount operation in the form of book credits, rather than in the form of currency. The smooth and successful work ing of a general clearing system will certainly aid greatly in bringing this about; 5th: It must be borne in mind that the Federal Reserve Banks do not control the situation. It is to be hoped that they will in time do so, but as yet, and so long as the National banks only repre sent one-third of the total number of banks numerically and one-half of the total deposits, it is obvious that they will not control and 7 1388 699- therefore that we must take into consideration the existence of the State hanks. So long as Federal Reserve notes and National hank notes can he counted as reserve hy State institutions, it must he admitted that that fact alone gives a great advantage to those institutions, while it throws upon the Federal Reserve System the burden of printing and emitting the notes and the responsibility of Sustaining the credit of the country; 6th: Furthermore, there is a condition which applies to all National hanks which is open to serious objection; to wit! sorting out of different classes of currency. the constant For example, a National hank keeps at the base or foundation of its reserve fund gold and gold certificates. icates. Next above this will come the silver and silver certif Next, the greenbacks* These three kinds of money, or sub stitutes for money, may be all classed as legal reserves, but, in ad dition to this, the bank may find it necessary to use three other forms of currency: National bank notes, Federal Reserve Bank notes, and Federal Reserve notes. In times of active demand for money, when * banks are holding little, ii anything, in excess of their minimum of reserves it becomes obviously necessary to push out this other currency, which can not be legally counted as reserves. If equally times come the effect of this policy is at once to cause the general public to differentiate between the various kinds of currency, and some times this differentiation goes to the extreme of hoarding the lawful reserve money, and pushing out currency which is not reserve. It is in times 1369 like these that Stave hanks, while having the advantage of calling any kind of currency reserve, may at the same time, serve the useful purpose of enabling National hanks to get rid of the currency which is not reserve - at least an anomalous situation. 7th: Those who are strongest in favor of counting Federal Reserve notes as reserves, even if it is only to a limited extent, point out that it is not proposed to let Federal Reserve notes he counted as reserve by the issuing Reserve Banks nor hy any other Federal Reserve Bank. They admit that such a policy would he had and would run counter to the general principles of credit currency. They further argue that to permit Federal Reserve notes to he counted as reserve to a limited extent hy National hanks in the Districts where issued is not dangerous because the Federal Reserve Board has, through its control of the re discounting privilege, an absolute control of the .emission of such currency. If, instead of only twelve hanks of issue, there were 100 or more, it is quite conceivable that the issue power might lead to enormous inflation, hut considering that this power is limited to 12, at the most, and considering the control of the Federal Reserve Banks over "the rediscounting privilege, it is, they argue, perfectly safe to permit member hanks to count as reserve to a limited extent Federal Reserve notes of their own Districts. 8th: It is a notorious fact that in ordinary times all forms of currency pass readily as of equal value and it is only in times of stress that real money, such as coin, becomes of special value as the basis of credit currency. Based on this fact it is urged that it is •1370 699- 7 - wise for the Central or Regional Banks to accumulate or impound gold. Thus a Reserve Bank which may have emitted one million of Reserve notes may at the end of three months have its rediscounts paid off in gold or the equivalent. It is wiser., it is argued., for the hank to keep out its notes and hold the gold than to pay out the gold and retire its notes, for the reason that the gold is of greater potentiality in times of trouble. 9th: Fdr obvious reasons it is most important that every thing in reason should be done to strengthen the regional banks, as reserve institutions. As has been often said, the Aldrich-Vreeland Act was an adequate scheme for the issuance of currency in times of stress. The Federal Reserve Act,on the other hand, aims to accom plish far more than that and not simply to act as an emergency bank even though amply endowed with currency issuing functions. It seeks among other things to accomplish the important function of steadying and equalizing interest rates and fortifying the country in advance against possible or sudden market fluctuations or heavy withdrawals of gold, due to changes in trade balance. If you permit the Federal Reserve Banks, it is argued, to reinforce themselves with gold in times when maney is abundant, they will be the better able .to act as shock absorbers in times of stringency, or great demand. ,1371 699 * III In conclusion, after giving the matter very full consideration, it is "believed that Congress may safely grant National hanks the right to count Federal Reserve notes of their own district as reserves* to the extent of say one-quarter or one-third of the reserves required to he held in their own vaults. It is believed that the effect of such a provision will tend to strengthen the Federal Reserve Banks and cause a gradual flow of gold to them. It is further believed that in times of actual demand for credit, when National hanks are running close on reserve, they will not hesitate to take Federal Reserve notes; whereas, if they are not per mitted to hold Federal Reserve notes as partial reserve, there wall he a disposition to regard Federal Reserve notes as inferior to other forms of currency. Furthermore, if, in the opinion of Congress, it is desirable gradually to replace National hank notes with Federal Reserve notes, it can he accomplished far more easily if Federal Reserve notes can he counted as reserve. F. A. DELANO