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TO ALL FEDERAL RESERVE AGEHTS E-LCriPT DALLAS. ; 437 FEDERAL RESERVE BOARD WASHINGTON address official correspondence t o t h e federal reserve board SUBJECT: x l n o v e m b e r „ 7 6 8 s 1 / , i v 66* Employment of Trust Examiners. Dear S i r : In connection w i t h t h e employment by t h e F e d e r a l Reserve Agents of t r u s t examiners, r e f e r r e d t o i n t h e Board's l e t t e r dated August 31, 1933, X-7576, the F e d e r a l Reserve Agent a t Dallas has raised the following questions: 1. 2# Am I c o r r e c t i n assuming t h a t the person appointed t o t h e p o s i t i o n of Federal r e s e r v e t r u s t examiner should p o s s e s s a l l t h r e e of t h e f o l l o w i n g q u a l i f i c a t i o n s ? (a) Broad experience ( p r e f e r a b l y e x e c u t i v e ) i n t r u s t company or t r u s t department work* (b) Broad and s p e c i a l i z e d experience i n examinat i o n of t r u s t companies and/or t r u s t d e p a r t ments • (c) Extensive l e g a l t r a i n i n g or e d u c a t i o n . Does t h e Board d e s i r e us t o make r e g u l a r p e r i o d i c a l examinations of the t r u s t departments of a l l member banks i n our d i s t r i c t , or does i t p r e f e r t h a t we conf i n e t h e s e examinations t o those member banks whose t r u s t departments we have reason t o b e l i e v e a r e i n need of s p e c i a l a t t e n t i o n ? There i s a t t a c h e d h e r e t o f o r your i n f o r m a t i o n a copy of a l e t t e r addressed by t h e Board t o t h e F e d e r a l Reserve Agent a t Dallas i n reply. http://fraser.stlouisfed.org/ Inclosure. Federal Reserve Bank of St. Louis Very t r u l y yours, hr)cr\AsL£j^ Chester M o r r i l l , Secretary. X-7688-a 4.88 Mr. C. C. Walsh, Federal Reserve Agent, Federal Reserve Bank of Dallas, Dallas, Texas. November 17, 1933. Dear Mr. Walsh: Reference i s made to your l e t t e r of October 16 i n regard to the employment of a trust examiner at each Federal reserve bank and p a r t i c u l a r l y the q u a l i f i c a t i o n s of such an examiner and the scope of h i s duties* Assuming that the person who may be under consideration for s e l e c t i o n as a trust examiner i s familiar with the p r i n c i p l e s of accountancy and auditing, i t i s believed that in order to accomplish the best r e s u l t s in trust examination work he should have the q u a l i f i c a t i o n s set out i n your letter. Of course, the number of men possessing a l l these q u a l i f i c a t i o n s i s somewhat l i m i t e d , and i n the circumstances i t might be found necessary to forego the requirement of broad experience gained as an executive i n a trust department and to s e l e c t an individual with sound l e g a l training and broad experience i n examining trust departments, or i t might be necessary to s e l e c t a man who has not had a great deal of experience i n trust examination work. In such a case, however, i t would be e s s e n t i a l to s e l e c t one who not only possesses the q u a l i f i c a t i o n s as to l e g a l background and experience i n operation of a trust department, but also evidences by t r a i n ing, experience and otherwise an aptitude for examination work. The entire scope of the duties of a trust examiner, of course, cannot be sharply defined, but i t i s the view of the Board that when an examination i s made of a State "bank applying for membership i n the system which has a trust department, there should be an examination of that department by a q u a l i f i e d trust examiner, and that the trust department of every State member bank should be examined p e r i o d i c a l l y . As to national X—7688-a 439 banks, the r e s p o n s i b i l i t y of examining the trust departments l i e s , of course, primarily with the Comptroller of the Currency, "but in some cases trust departments of national banks may require special a t t e n t i o n and i t may be found mutually advantageous to have your trust examiner cooperate with the national bank examiners. In addition, there may be cases of national banks applying for permits to exercise trust powers i n order that they may be able to take over trust business previously handled by State i n s t i t u t i o n s , and i n such instances you should arrange for examinations of the trust departments of the State i n s t i t u t i o n s by your trust examiner, unless the necessary examinations have been made by other competent examiners whose reports are entirely satisfactory. Aside from the question of r e s p o n s i b i l i t y for making examinations i n the f i r s t instance, the trust examiner should be charged with the duty of reviewing c a r e f u l l y the reports of examination of both State and national banks which have trust powers and of f a m i l i a r i z i n g himself with the quality of management and methods of operation of such trust departments. He should also draft for your consideration such reports and recommendations as should be made by you to the Federal Reserve Board i n connection with trust matters. I f , after these duties are performed e f f i c i e n t l y , the trust examiner has any spare time, he should be able to render valuable assistance i n other work of your o f f i c e , particularly that r e l a t i n g to a f f i l i a t e s and the handling of applications for voting permits. On the whole, i t would seem that a properly q u a l i f i e d trust examiner could be so useful i n the Federal Reserve Agent's department in a l l of the more important phases of examination work that h i s time would be occupied f u l l y . Very truly yours, (Signed) Chester Morrill Chester Morrill, Secretary.