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FEDERAL RESERVE BOARD WASHINGTON M.C.ELLIOTT COUNSEL April 8, 1918· Mr. C. A. HinsCh, President. The American B.::..nkers Association, c/o Fifth-Third liationa.l :Ba.nk, Cincinnati, Ohio. Niy dear •vlr. Rinsch-: As requested, I have prepared. from the records in this office the accou~ying r.1e.t1orand\lJil with reference to State le~islation affectill6 r.:embership of State ban:l::i:i aud trut>t coLJpa.nies in the Federal Reserve Systetl· While I have a.ttei.pted to obtain tl~ latest available infon.--ation with reference to the sta.tus of State la•vs on this subject, I ba.ve not had an opportunity to have this aua.lyds checked by Couusel for the various Feder-d.l reserve banks or ·Jy tl1e State authorities and it is not iailibirly that inaccur&.cies ·.1111 be discovered. I will greatly appreciate it if you, or any of thO$e to \ihOiil this ,_,etlorandw:;l is referred, will call t~1e atte:ation of this office to any errors that are discovered· Under tb.e heading of "Legislation Hecessa.ry" in th(j several States, I ha-va I;~enti oned th~e I;atters which have not been specifically covered by statute. It is, of course, true that in .tany States the State authorities ara not prohibited fror.1 disclosine. to the Federal aU:thori ties inforrnation ·,Ji th refere.'1ce to ;,19,.:ber banl:s, a~1d where banks are parmi tted by State laws to becor.Je Lielilbers of the System they are necessarily sub"ected to exa;nnation by the Federal authorities. It is ·probable, therefore, that i t is not actually necessary to obtain sor.;e of the a~iend.;:.ents to State laws that are S"Ugt;ested iu the accoo!lanying rntlorandum. Not ·..\'ishil1g to undertaka to construe the State laws in these several particulars, I have s~ested as necessary aA.endJ,Jents to the State laws trwse :provisions which have been adopted by so.;e State;:; but have not been .:Mpressly included in the statutes enacted by the State under consideration. I trust this will :;ive you the infornation desired. With best ~ishes, Cordi&.lly yours, {Sif,ned) i1!. C~ ELLIOTT, Counsel·