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FEDERAL RESERVE BOARD
WASHINGTON
address official correspondence t o
the federal reserve board

X-9006
November 1, 1934.

Dear Sir:
Daring the meeting of Chairmen and other representatives of
the Industrial Advisory Committees i n Washington on September 27,
1934, there was a discussion of the status of the committees and
their r e l a t i o n s with the Federal reserve "banks under the i n d u s t r i a l
credit a c t .

A "brief digest of this discussion i s contained i n the

summary statement which was sent to you with the Board's l e t t e r ,
X-8031, of October 2, 1934.
As you know, Congress, i n establishing the Industrial Advisory
Committees, provided that each member should "be a c t i v e l y engaged i n
some i n d u s t r i a l pursuit within the Federal reserve d i s t r i c t i n which
the committee i s established; that each application should "be submitted to such committee; and, a f t e r examination by i t of the business
with respect to which the application i s made, that the a p p l i c a t i o n
should be transmitted to the bank with the recommendation of the committee .
As the enactment of t h i s new l e g i s l a t i o n was based upon the
b e l i e f that there were many established business enterprises whose needs
for working capital had not been met by banking i n s t i t u t i o n s , i t was




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320

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evidently the expectation of the Congress that establishment in each
d i s t r i c t of a body composed of carefully selected i n d u s t r i a l i s t s would
bring to bear in the f i r s t instance upon the problem submitted i n each
application the kind of independent judgment that would be most appropr i a t e for the determination of the question whether the loan desired
could be made on a sound and reasonable basis notwithstanding the r i s k s
and uncertainties that might have deterred banks from making such loans.
It i s important, therefore, i n order to carry out the obvious
intent of the Congress that the Industrial Advisory Committee s h a l l be
f r e e to use such means and methods as they may deem necessary in order
to enable them not only to make the examinations required by the law but
to exercise their independent judgment i n making their recommendations
to the Federal reserve banks.
The question has arisen, however, whether the o f f i c e r s of the
banks, i n a s p i r i t of cooperation and a desire quickly to reach harmonious
conclusions, may have overlooked the purpose of Congress as to the precedent and independent p o s i t i o n of the committees and have attempted to i n fluence the members of the committees to adopt views which the o f f i c e r s ,
in the l i g h t of their own banking experience, f e l t should apply to the
f i n a l d i s p o s i t i o n of the applications.

However sound such views might

be and however commendable the desire to a s s i s t , the Board f e e l s that i t
should point out the a d v i s a b i l i t y on the part of the o f f i c e r s of the
banks of refraining from any form of action with respect to the proceedings of the committees which might seem to j u s t i f y c r i t i c i s m s in the



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future that the recommendations of the Industrial Advisory Committees
v/ere reached otherwise than through the e x e r c i s e of t h e i r independent
judgment.

This expression of the Board's f e e l i n g i n t h i s matter of

course should not be interpreted as r e s t r i c t i n g i n any degree the
freedom of the committee to c a l l for any a s s i s t a n c e that i t may need
and i t i s expected that the i n v e s t i g a t o r s who prepare data f o r submission to the committees w i l l include i n t h e i r reports a l l pertinent data
that they have been a b l e to gather regarding the condition, management,
e t c . , of the a p p l i c a n t , both of a favorable and unfavorable nature, i n
order that the committees may be i n p o s s e s s i o n of a l l the f a c t s which
the i n v e s t i g a t o r s have been able to a s c e r t a i n .
Very truly yours,

Chester M o r r i l l ,
Secretary.

TO GOVERNORS AND AGENTS OF ALL F. R. BANKS.