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371

BOARD OF G O V E R N O R S
O F THE

FEDERAL RESERVE SYSTEM
S-399

WASHINGTON

ADORCBS OFFICIAL OOHREBFONDCNCE
TO THE BOARD

December 5> 1941

Dear Sir:
In 1937 the Board requested one of the members of its legal staff
to make a survey of the legal divisions of the Federal Reserve Banks. Following the submission of the reports of these surveys the Board, in June 193fi>
adopted a resolution in which, in view of the material differences in the
practices of the Federal Reserve Banks with respect to the employment of
counsel and the manner in which their legal work was handled, the position
was taken that as a matter of general policy the legal work of each Federal
Reserve Bank should be conducted under the direction of a full-time general
counsel who represents only the Federal Reserve Bank; that, however, with
"respect to the Banks which did not have such counsel the adoption of this
polity should be regarded as an ultimate objective to be attained when circumstances permitted without disturbing existing arrangements if otherwise
satisfactory; and that the President of each Federal Reserve Bank should
be advised that it was the desire of the Board to be consulted informally
before the Bank made any change in the manner of conducting its legal work
or the principal personnel engaged therein.
Advice of the adpption of the policy as set forth in the resolution was not sent to the Federal Reserve Banks at the time for the reason
that it was felt that the policy could be brought to the attention of the
respective Federal Reserve Banks as occasion might require, but in accordance with the last clause of the resolution a letter was sent to the President of each of the Federal Reserve Banks on June 8, 1938, stating that
it would be appreciated if, whenever circumstances developed in the future
indicating the desirability of a change in the principal legal personnel
or the manner in which the legal work of the Bank was conducted, the Bank
would advise the Board informally before action was taken.
Recently the Board has'had occasion to reconsider and reaffirm
the polity as set forth above and requested that all Federal Reserve Banks
be advised of the position which the Board had taken.
Very truly yours,

TO THE PRESIDENTS OF ALL
FEDERAL RESERVE BANKS




Chester Morrill, .
Secretary,