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X-375.
PAUL
WILLIAM

C O M P TR OLLER O F TH E C U R R E N C Y

M. W A R B U R G , V I C E G O V E R N O R

F R E D E R I C A. D E L A N O
A D O L P H C. M I L L E R

G. Mc A DO O

SECRETAR Y OF TH E TREASURY
C H A IR M A N
J OH N S K EL T O N W I L L I A M S

CHARLES S. HAML IN

FEDERAL RESERVE BOARD

H. PARKER WILL IS , S E C R E TA R Y
S H E R M A N P. A L L E N , A S S T . S E C R E T A R Y
and

F is c a l A g e n t

ADDRESS REPLY TOFEDERAL RESERVE BOARD

W A S H IN G T O N

September* 14, 1917,.

Dear Sir:
The Board has received through the Secretary of the
Treasury an opinion by the Acting Attorney General of the
United States regarding the charter and statutory rights of
those State banks and trust companies which become members of
the Federal Reserve System,
A copy of this opinion is transmitted to you herewith
and your attention is especially directed to the quotations from
Section 8 of the Clayton Act which appear at the bottom of the
first and the top of the second page. You will note that the
conclusion is reached that National b~nks and all banks and trust
companies in the District of Columbia come within the prohibition
of Section 8 of the Clayton Act; but that, those State bank3 and
trust companies which join the Federal Reserve System and which
do not operate "under the laws of the United States as the laws
of their existence, nor in ^territory over which the United States
exercises exclusive legislation" are held to be free from the
restrictions imposed by Section 8 of the Clayton Act as quoted
in the opinion.
You are informed that the Federal Reserve Board will
be governed by this opinion, and that its regulations relating
to interlocking directorates will be modified accordingly.
Please bring this to the attention of the St^te banks and trust
companies of your district.
Very truly yours,

Governor.

Inclosures.




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W . P. G . H A R D I N G , G O V E R N O R

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