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r https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Collection: Paul A. Volcker Papers Call Number: MC279 Box 10 Preferred Citation: Congressional Correspondence, October 1980; Paul A. Volcker Papers, Box 10; Public Policy Papers, Department of Rare Books and Special Collections, Princeton University Library Find it online: http://findingaids.princeton.edu/collections/MC279/c434 and https://fraser.sdouisfed.org/archival/5297 The digitization ofthis collection was made possible by the Federal Reserve Bank of St. Louis. From the collections of the Seeley G. Mudd Manuscript Library, Princeton, NJ These documents can only be used for educational and research purposes ("fair use") as per United States copyright law. By accessing this file, all users agree that their use falls within fair use as defined by the copyright law of the United States. 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Mudd Manuscript Library 65 Olden Street Princeton, NJ 08540 609-258-6345 609-258-3385 (fax) mudd(&,princeton.edu https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis .• .• ofGovt/i• • •• • BOARD OF GOVERNORS •co .• )t• Ln• •.(c, rIF THE FEDERAL RESERVE SYSTEM WASHINGTON, 0. E. 20551 RALizts•' • • .. • • PAUL A. VOLCKER CHAIRMAN October 1, 1980 The Honorable Edwin B. Fo rsythe Member of Congress P. 0. Box 128 Moorestown, New Jersey 08057 Dear Mr. Forsythe: Thank you for your lett er of September 17 regard correspondence you receiv ing ed from Mrs. Celia Horw itz requesting assistance in obtaining a replacement check fo r a $394.10 discount check that she did not receive. The discou nt check was issued in connection with Mrs. Horwitz's purchase of a $10,000 six-month Treasury bill. Board staff has contacte d the Division of Chec at the Treasury Departme k Claims nt and has learned that Mrs. Horwitz's stop payment order was entered on July 14, 19 80. The Treasury's records also show that Mrs. Horwitz's discount check has been cashed. They are now in the process of looking into nrs. Horwitz's request. In order to ex pedite a resolution of this case, we are forwarding your inquiry to the Treasury Departme nt. I am sure you will be hearing fr om them in the near futu re. Sincerely, ,kaaill A. Yolckec vcd (0T-371) ix. Wallace 11. QU ::alaardi (2) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • q9 GOIAt • BOARD OF GOVERNOR5 OF TI-Ir •• FEDERAL RESERVE SYSTEM WASH1NGTON.O.C. 20551 October 1, 1980 Department of the Treasury Bureau of Government Financial Operations Congressional Claims Branch Division of Check Claims 401 14th Street, S.W. Washington, D.C. 20227 Dear Sir: Enclosed is a copy of an inquiry that we received from Congressman Edwin B. Forsythe. Congressman Forsythe's constituent, Mrs. Celia Horwitz, submitted an Advice of Request for Stop Payment on July 1, 1980, for a discount check in the amount of . Since Mrs. Horwitz submitted her request, she has received no response to her claim. We would appreciate your investigating Mrs. Horwitz's request and responding to Congressman Forsythe directly. . Thank you for your assistance. Sincerely, (Signed) Donald J. Winn Donald J. Winn Special Assistant to the Board Enclosure 141Y3mrk (0V-371) bac; Zr. Wallace Ms, Young Mallardi (2) Aden assigned Mr. Wallace I C.DWIN El. FORSYTHE • 303 CANN•IN l'iCRPCI" OF ICE Buitmtmo WAsortwaro... D C. • 20515 WHOSE R Commirrt M ERCHANT MARINE AND FISHERIES 2C2-225-4765 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Commtr-Try Congros5 of die Unitcb cptate5 31)oufse of 3AtprefSentatiins5 Ulasnton, 20515 Scitnice ANO Trcm4ouoor trim0F, i September 17, 1980 /1 1,) 14/ Hr. Paul A. Volcker, Chairman Bd. of Governors of the Federal Reserve System 20th & Constitution Ave NW Washington, D. C. 20551 Dear Nr. Volcker: The attached correspondence from Nrs. Celia horwitz is sent for your consideration and review. I would appreciate it if you could investigate this matter as soon as possible. Your necessary tuent and with your assistance in providing me with the information for replying to my consti— returning the enclosed correspondence answer would be most helpful. Thank you very much for your time and efforts in responding to this request. romilimmo. Sincerely, 'qv Edwin B. Forsythe Nember of Congress LBF/pd Enclosure P.S. Please reply to: P.O. Box 128, Hoorestown, New Jersey 08057. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis JACK FiNNITZ, 0 P. M. • SURGE' 'I PODIATRIST SEP. 1 463 InalA STREFT OURLING1ON TilLaPHONIE N .J. oso 6 366-0124 September 11, 1980 Congressmen Edwin B. Forsythe F. 0 Box 128 Yoorestown, N. J. G6C57 Dear Congressman Forsythe: I Purchased a 6 month Treasury Bill for on May 29, 1980. The account # is with a discount amount of . A copy of the "statement of account" with all the pertinent information identifying the account is attached. I never received my discount check for = ;Es: I c . I waitdd a reasonable time and then notified the Federal Re— serve Bank of Philadelphia where the Bill was bought that I had not yet received my interest for the "bill". The Federal Reserve Bank of Philadelphia sent me an "Advice for Request for Stop rayment" together with a covering letter, a copy of each is also attached, herewith. Both of these are dated July 1, 1960. Until today I have received no reply from my Government. Be— tween duly 1C, 1980 and September 10, 1980 I have telephoned and written to both the Federal Reserve Rank Of Philadelphia and to the Bureau of the Public Debt in Washington, D. C. sev— eral times but to no avail. No one knows anything about anything. Whet makes it most frus— trating is that to whomsoever I speak refuses to give me a name for future reference. Congressman Forsythe, I would be most appreciative if you would use your good offices to cajole your government and mine to please send me which they now owe me for over 3 months. I'll be satisfied to forgo the interest. Very sincerely yours, 1-16-11-4.(• Celia Horwitz kr4 STATEIJENT OF ACCOUNT Ei.,:-.E4u Or THE RUkLIC DL x DC 20226 BOOK-ENTOsECURITIES TELEPHONE 'o:(202) 287.4113 TELEPHONE No FOR DEAF: (202) 2A7- 4097 CELIA THIS STATEmENT IS NOT NEGoTIAsLE W]RbsITZ YOUR ACCOUNT NUmBER:= = = STATEMENT DATE: 06/1 9/80 =. ESS ABOVE, PLEASE = :HEN rORRESPONOING ARITE TO THE TREASURY ADDR AS SHOwN ON THIS STATEMENT, ALL CHANGES= =INCLUDE YOUR ACCOUNT NUMBER c AT THE BUREAU BY: 10/29/80 =FOP THIS BILL ACCOUNT MUST BE RECEIVED DESCRIPTION OF SECURITIES: TREASURY BILLS TYPE OF SECURITY 031-18557 FRB REQUEST NO: 912793505 CUSIP NUMBER: 05/29/60 ISSUE DATE: 1 1 /28/80 riATURITY DATE: 39a.10 DISCOUNT AMOUNT: 110.01.4879 SOCIAL SECURITY OR EMPLOYEE ID NO: AMOUNT CURREJ.T STATUS OF ACCOUNT! BALANCE 10,000 As OF STATEMENT DATE 0 TO BE REINVESTED: 10,000 TO BE REDEEMED: 03603977 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 4L-t -6 0 /t i --451 i(Li •AZ /4 "P‘ FEDERAL ULSI=HVE BANK OF PHILADELPHIA SECURITIES DIVISION POST OFFICL BOA 90 PtilLADELPHIA PINNSV1VAN:A IQIC July 1, 1980 . Dear: Mr. Horwitz We are sorry that you have not received your check of discount from your Treasury Bill. You will hear from the Treasury in Washington in the next several weeks . They will send you a discount check to cover the one you did not receive. Please keep this yellow copy that is enclosed with this letter. Thank you, Federal Reserve Bank of Pa. Securities Division •00,44, kofk"ii I‘O • "op 5/ FISCAL AGENT OF THE UNITED STATES https://fraser.stlouisfed.org • Federal Reserve Bank of St. Louis • - •16/9.- •••• . • • 11917-C •••i Memo No.6 (REvl •• ADVICE OF REQUEST FOR STOP PAYMENT --r 4 - (forward to Pc..• or Cio;mant) _ t of F.eqJest. 2. 7/1/80 P1131011 . 0 "X" if confinnaticxi . ..1, 3. Ahlount , ... 4. D.of Oydc 1.5. Symbol,_ . 6. 04.1.k P's'-ber ILI:c.n.ceIpi ' 0to" -' •D Stol•ii. - si94.0. ..0 04;.,.., :/..,...-...,L0 ...- if corryci:on -Si29/110 . 4870 102.65741 1 ryee's Norr.• j•nt•r only • r. pc' idenrcof to thilnrri. . CI PI ant.; nom* in Box 9 f ',1" • rir% 79 E iernarki (inducing identification or (*Ferenc') 9. Claimant of Cheek and Current Addrei4 : see sittached-71 DC - RE-Lorr OLU imirrz-tr? IF21.1ED.I.0 i.17.Elj o, rpc re-'7-463 HIGH STRaT 'Pc -1-.•-""‘ ()Merle6/1.Yr 1 A .•A •• • • •BouNcrai N.J. • tr-..epp Ipir cant- it;:rctc-r: ..t. 'P" / • c•-it IPITT' r nzpoLmi-ci ;) 7.1'ç Lc 7.• T. tun n vat rryc at9'co &Jul; ml.111. nit It 14-T2:71‘1. C: •;•71:-.1" z Arra CPccr Cr: Y-AD DV.L£ T.:2 I '7`,..-11 oloie'r- 10. VIDT10E TO PAYEE OR CLA.IMANT;cr . • yet,. crT:par, at !!-F3..-n't77.7C11." LrTJp=• f "Tr La rIctir,ibie 10.1.1G. • yornq fiev•pc:F! /arr._ sitr.nrric wog L•7:7z irccrr-Tn4) CF.C1.21E' Cr- CYCCT .• r -- --...-7... u,er-c-.---)". -,----• • IF r-vrin --..r----• - •--•--•- - -•••-- -- --••---- •• .;:-. 9 '''''' .i. : — •*" .9Your ciaim is being,handled • the Office or the-freas-urer °Tule United States Check Claims Division, N% aslungton, 'D.C.20226. "" •-4 " g'. ' UT::- 't ,.. ^..;" n' ....." rIllirt-17"7. Pt:: r•-•„•:-/. , • ny.....q.ia 1X., •-.00.. LT-•!.:1 *IN •L'it.... £1.11C1 s.....4 • 22 2.00C SI Pleace react -and-carefully observe me instructions on t e other racie or(his orm. .. 1. IL ACYcl HVAE VIISLYDA CV2IIED .1-i-1' re CHECE4 -1.112 ii.OLifi 213011.1-1)Er D12-11.-0.7dir .'O .EL OJ GriIIPIY10.1; t • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • -4"• -:ai J'" A • " - C/1/1 (ctu..-1 2, TYe Honorable Lilliam Prox.14.ire Chairman ittee o:. 5an)vinl, cusirt and Urban Affairs ;;tates Senate 20510 intor,r;.C. Dear Chairman Proxmire I am 1,1eaved to forward “*eliminery reforts on actitins taken so far by the Fe4eral reserve to implement the :„.onestary Control Act of 1980 (Title I of P.L. 9C-221), and on the actions taRen thus far by the repasitory institutions Deregulation Committee. These relorts were undertaken at the raquest of CI:airman Leuas of the. House Committee on Banl-ing, Finance') sr-1;i Ce.An Affair. A1cn4; with the rei,orta, I am enclosing cories of various relevant regulationv, rrens relelses, and staff mamotanda. Sincerely, SLPalll A. Identical ltrs. to Sen. Carn & Cong. Etantor. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • Enclosures: P. R. dtd. 3/31/80 P.R. dtd. 4/17/80 Ltr. to Executive Officer of Commer cial Banks from Chrmn. dtd. 4/17/80. ' P.R. dtd. 4/23/80 P.R. dtd. 6/4/80 P.R. dtd. 6/10/80 P.R. dtd. 6/26/80 Memo to Board from Mr. Axilrod re Reg . D dtd. 7/31/80 Memo to Board from Discount Policy Gro up re Reg. A dtd. 7/31/80 Memo to Board from R&S & Legal Divs. re Public Comments on Proposed Pass-Through Guidelines dtd . 8/8/80 P.R. dtd. 4/11/80 Memo to Board from Bk.Ops,R&S,Legal Divs. re Federal Reserve Float dtd. 8/15/80 P.R. dtd. 8/15/80 P.R. dtd. 8/27/80 P.R. dtd. 8/28/80 Memo to DIDC from DIDC staff re Sel ection of Chrmn. and Initial Organizational Decisions dtd. 5/2/80 , Memo to DIDC from DIDC staff re Interest as a Deposit for Purposes of the Early Withdrawal Penalty Rul e; Payment of Interest After Maturity dtd. 5/2/80 Memo to DIDC from DIDC staff re Pre miums and Finders Fees dtd. 5/2/80 r' P.R. from DIDC dtd. 5/7/80 P.R. from DIDC dtd. 5/13/80 RXRXXXMMXHINEXIAXXXXHX2URR Memo to DIDC from DIDC staff re Adj usting Rate Ceilings on Variable Ceiling Deposits dtd. 5/27/ 80 P.R. from DIDC dtd. 5/29/80 P.R. from DIDC dtd. 6/4/80 P.R. from DIDC dtd. 6/6/80 P.R. from DIDC dtd. 6/10/80 Memo to DIDC from DIDC staff re Ear ly Withdrawal from IRA and Keogh Accounts dtd. 6/20/80 Memo to DIDC from DIDC staff re Con gressional request for comment on money market mutual fund-type acc ounts for depository institutions dtd. 6/20/80 Memo to DIDC from DIDC staff re Dep osit Rate Ceilings on Interestbearing Household Transaction Accoun ts dtd. 6/20/80 Memo to DIDC from DIDC staff re Rhode Island Petition dtd. 6/23/80 P.R. from DIDC dtd. 6/30/80 Memo to DIDC from DIDC staff re Deposit Rate Ceilings on Interestbearing Household Transaction Acc ounts dtd. 9/3/80 Memo to DIDC from DIDC staff re Actions Relating to the Authorization of 14-29 Day Time Deposits dtd. 9/4/80 Memo to DIDC from DIDC staff re Pro posed Rules on Premiums and Finders Fees dtd. 9/5/80 Charts Accompanying Briefing on Savings Deposit Flows--dtd. 9/9/80 by Dale P. Riordan of FHLBB. The Wonora;.4a Donale, : , :tewart Unitad rotates Sotate ;ias2A.n.;;t4n, D.C. 2:;510 rsear n414. T:lank you forLatter of Scir.,tember 10, concerning ext -ankerts LArnk exeog,tion fr4m. ro4t.erve r4.tuirt-T,Aentr t)q, 141motapxy Control Act. Lest Wednesaa l the Board ditcuscat,O. critaria to be wi/Ilied in order to cnalify for the oxenptiou. ittailes CA, Aet ? .oeitQr7 iLstitution im a .skni.ars• bant if it doez not d4 aesis with t.k41 general putlia. Consiatert -41tA CAt iLttaat of Coalreas, the. Board determined that zu inmtitattoo that dtiagiseis deti,ogits txrs .rat *neonate *f no more than 1C ,er Gent of itP total lielil!tic,n front or imakes loans of .ncre than 4-er cent ot total as,:ot:: to r ccrtain United custo3ers sue ma 4f:tit:era or directorr cf ethr credit unions, zeml.ortg of faiLA credit Uhi0114, or trade associations 4anarally vould vivalif.; for the 1... 11clai bank exmption. based upon Vla ialorz4atie4 vrcseutad, Alaaaa Central would al,pear tr have 4144usts and IluLilitias attrJtAital:le to individuals in excess of tLe 10 ter oent litAts and tl.orafore would not ap;-ear to at t!lt1 tiz.c for t:Alt czomi=tion from revery* requirelorto. • tc.2 diteuso the noard's IrteiretAtion wit fAaff AlaY4r.A Cautral to deterine eutent !,4z. tlees wit*r. CAI gencral nverc; of( elc ii17441141 ct tAssine3v to t crydit TAs al4To4c1; voul4 AltAin" onak4a Ala;,;ima CcIttral tx=• t.kr thc ":..;a4rA io , Lot rotx 6Va iwjt (01-370) Cil Schwartz Lcual Lecords (2) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis t. '7.73tter. Action assigned Mr. Petersen DONALD W. STEWART STATE OFFICES! ALABAMA MONTGOMERY COMMITTEES: AGRICULTURE. NUTRITION. AND FORESTRY cwEA ,RMAN SUF3CoMmETTE-E ON AGRicuLTuRAL RESEARCH AND GENF PAL LFGISLATION — -RURAL CE VELOPMENT — ENVIRONMENT. SOIL CONSERVATION. AND FORESTRY ?Anitcb 'Zfalcz mate FEDERAL BUILDING 474 SOUTH COURT STREET MONTGOMERY. ALABAMA 36104 (205) 832-7600 BIRMINGHAM WASHINGTON. D.C. 20510 September 10, 1980 FrorRAL BUILDING 18o0 5TH AVENUE NORTH BIRMINGHAM, ALABAMA 35203 (205) 254-1288 M013ILE 3280 DAUPHIN STREET 13UILDING MosiLr. ALABAMA 38604 (205) 690-3125 BANKING, HOUSING. AND URBAN AFFAIRS CHAIRMAN ANN ISTON INSURANCE SUBCOMMITTEE FINANCIAL INSTITUTIONS FEDERAL BUILDING 1129 NoeLt Srvetrr ANNISTON, ALABAMA 36201 (205) 237-5993 SMALL BUSINESS HUNTSVILLE GOVERNMENT REGULATION 500 LOWELL DRIVE BUILDING 2.0 HUNTSVILLE ALABAMA 35801 (200 , 538-4493 RURAL HOUSING GOVERNMENT PROCUREMENT The Honorable Paul Volcker Chairman, Federal Reserve Board 20th and Constitution Ave. NW Washington, DC 20551 Dear Mr. Chairman: 14' I have attached a letter from the Alabama Central Credit Union which discusses a concern they and other central credit unions have with the "banker's bank" provision of Regulation D, which is presently being considered by the Board. It is my understanding that any institution under the definition of a "banker's bank" would be exempt from placing reserves against their transactions accounts. The Alabama Central Credit Union serves both institutions and individuals and is concerned that it may be required to hold reserves not only against its individual accounts but against its institutional accounts as well. tA'arlif.• , The President of the Alabama Central Credit Union, his legal counsel and a member of my staff have met with Federal Reserve staffers and fully discussed the nature and extent of this problem. We felt that the response from the Fed staffers was very good and that an equitable solution was certainly within reach. I feel strongly that this is the type of case which merits the kind of flexible regulatory consideration that you and I have discussed in the past. Sincerely, e. 'bog- Donald W. Stewart United States Senator DWS/jr https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis THIS PAPER IS 100% RECYCLED FIBER. 011'711 ALABAMA CENTRAL CREDIT UNION 61 t3.1, AVFNUE SOUTH P. 0 BOX 10324 BIRMINGHAM, ALA. 35202 TELEPHONE 252-8031 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis September 3, 1980 Mr. Theodore E. Allison Board of Governors of the Federal Reserve System 20th Street at Constitution Avenue, Northwest Washington, D. C. 20551 Re: Monetary Control Act "Bankers' Bank" Exclusion Dear Mr. Allison: Alabama Central Credit Union wishes to make certain comments regarding the "Bankers' Bank" exclusion from reserves required by the Monetary Control Act (P.L. 96-221) and regulations promulgated pursuant thereto. Alabama Central Credit Union is a credit union which was organized under state law in 1938 to serve its members, consisting of other credit unions and the officials of other credit unions. Throughout its history, the credit union has served not only credit union members, but also individual members. As of August 31, 1980, Alabama Central had approximately $77,000,000 of corporate assets and $20,000,000 of individual assets. Alabama Central Credit Union is concerned that it will be required to maintain reserves on all of the deposits which represent its corporate deposits, when such reserves are not required if it reorganized into a "pure corporate" credit union. This result might be required by the provisions of the "Bankers' Bank" exclusion contained in .201.1(c)(4) as follows: "This Part does not apply to any financial institution that (i)is organized solely to do business with other financial institutions; (ii)is owned primarily by the financial institutions with Mr. Theodore E. Allison Page 2 September 3, 1980 which it does business; and (iii)does not do business with the general public." The above exemption is, of course, simply a restatement of the statutory exemption which appears in §103(9) of the Act. Obviously, Alabama Central Credit Union could avoid any reserve requirements for its corporate business if it would "spin-off" its corporate functions from its individual functions. We know of no congressional policy which this would advance and feel that some consideration should be given to requiring such reserves for Alabama Central as would be necessary if the credit union had reorganized into two separate credit unions. Essentially, this would permit Alabama Central to continue to do business in its present form, but require reserves for transaction accounts like any other credit union. This result would be achieved by recognizing the "Bankers' Bank" exclusion as applying to Alabama Central Credit Union's corporate deposits. Certainly, the "Bankers' Bank" exception should not be applied to all credit unions, but only to credit unions whose major function is being a "credit union's credit union". In this connection, the Central Liquidity Fund provides for a 51% requirement for existing central credit unions and the NCUA provides for a 75% requirement in chartering a new corporate "central credit union". The NCUA regulations define a credit union as a corporate central credit union as follows: "Corporate central Federal credit union' means a Federal credit union operated for the primary purpose of serving corporate accounts. A Federal credit union will be deemed to be a corporate central Federal credit union when its total dollar amount of outstanding https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis L https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. Theodore E. Allison Page 3 September 3, 1980 corporate loans plus corporate shareholdings is equal to or in excess of 75 per centus of its total outstanding loans plus shareholdings." One of the difficulties with the above definition is that it does not recognize corporate funds which are invested in anything other than loans to credit unions as "corporate". Therefore, if a credit union had 75% of its deposits from credit unions (but had no outstanding loans to credit unions) and had the remaining 25% loaned to individuals, the credit union would have 75/125ths "corporate business" as defined by the above formula. Obviously, credit union members tend to all need either loans or investments at about the same time. It is, therefore, obvious that at certain times the deposits of credit unions will not be reflected by loans back to the credit unions, but by investments. Whether the credit union members need loans or investments at a particular time does not really detract from whether a credit union is more or less corporate. However, a definition such as is described above might have the unfortunate effect of having a credit union meet the test at one point in time and not meet the test the next day. The NCUA regulations which permit participation in the National Credit Union Central Liquidity Fund (pursuant to the National Credit Union Central Facility Act, Subchapter III of the Federal Credit Union Act) deals with this problem by defining a central credit union as follows: 'Central credit union' means a Federal or state-chartered credit union primarily serving other credit unions. A credit union is primarily serving other credit unions when the total dollar amount of the shares and deposits received from other credit unions plus loans to other credit unions exceeds 50 percent of the total dollar https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • Mr. Theodore E. Allison Page 4 September 3, 1980 amount of all shares and deposits plus loans during the qualifying period, as defined in subsection (o) of this section." Certainly the percentage figures for qualification in the Central Liquidity Fund are less likely to result in any institution waivering as to its qualifications. In summary, Alabama Central Credit Union believes that it should not be required to undergo an artificially contrived reorganization in order to avoid reserving on its corporate business. The most practical solution is permitting credit unions like it which are basically "credit unions' credit unions" to come within the "Bankers' Bank" exemption with reference to their credit union deposits. To permit this to be done would not detract from any of the policy which prompted the Monetary Control Act, but would permit the market place to determine whether "mixed" corIS rate centrals can adequately serve their corporate memS.rs. Very truly yours, ALABAMA CENTRAL .EDIT UNION (/ William Ec%aOrdan, President WEJ/lw CC: Alabama Credit Union League 617 - 37th Street South 35222 Birmingham, Alabama U.S. Central Credit Union P. 0. Box 431 Madison, Wisconcin 53701 Ak-4r, r\- . • rLe v- BOARD OF GOVERNORS F.; THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20 551 PAUL A. VOLCKER CHAIRMAN October 2, 1980 The Honorable Ed Jones House of Representatives Washington, D.C. 20515 Dear Mr. Jones: Thank you for giving me the opport unity to comment on the recent letter from your consti tuent, Mr. John Clinton. Mr. Clinton is concerned with the effect of high interest rates on small businesses and farmers and the role of the Federal Reserve in causing those rates. High interest rates are primarily the result of the rapid rate of inflation we are exp eriencing and the deeply embedded expectations that prices wil l continue to climb. In this environment, interest rates are high because demands for credit to finance purchases are strong , while lenders are reluctant to extend credit without being compensated for the declining value of the dollars they will rec eive in repayment. The Federal Reserve might be able to offset the se effects temporarily by encouraging more rapid expansion of money and credit, but this would only increase inflationary pressure in our economy over the long run. The most prudent course for the Federal Reserve to follow in the present situation is to lower the growth of the money stock gradually. Such a pol icy, over time, will reduce our inflationary spiral and allow interest rates to fall to lower levels. We are pursuing a policy of slower monetary growth not by manipulating interest rates the mselves, but rather by controlling the growth of bank reserves. This approach, which we have been following since October 6, 1979, is expected to give us closer control over the money sto ck and, thereby, promote a higher degree of stability in the economy. An unavoidable byproduct of the reserve approach, how ever, is that interest rates are determined solely by market for ces. With the new control procedures, therefore, we can expect larger and more frequent interest rate fluctuations. Mr. Clinton is correct in pointing out that responsible fiscal policy is an essential element in improving conditions in our credit markets. A reduction in gov ernment spending will help reduce inflation and limit the need for government borrowing, both of which will allow interest rates to fall. https://fraser.stlouisfed.org MFederal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The Honorable Ed Jones Paye Two I understand the pr oblems that high cause some borrower interest rates can s. Over the long run, however, your will best be served constituent by monetary and fiscal policies de remove inflationary signed to biases and to crea te a stable econom ment in which busi ic environnesses can thrive and expand. I be Federal Reserve is lieve the pursuing a course that will contribu more prosperous ec te to a onomic situation. Sincerely, MM:DK:JLK:pjt (#V-37 2) bcc: Mr. Kichline Mr. Kohn Mr. Moran Mrs. Mallardi (2) 0 • ED JONES Actiontsigned Jim Kichline • 7TP-fp DISTRICT. TENNESSEE • 108 C.ANNotl H°usr OFFICE BUIUDING oisTarcr orricrq. Room 13-7. POST Orricr BUILDING JACKSON, TENNESSEE 38301 (202) 225-4714 • COMMITTEE ON AGRICULTURE (901) 423-4848 Congress of tije Ziniteb tate5 cwikimmAki. SUBCOMMITTEE ON CONSERVATION AND CREDIT COMMITTUr ON HOUSk; ADMINI:aiRATION CHAIRMAN. SUBCOM M ITTEE ON HOUSE SERVICES 3Ti)oucse of iltpressentatibeg tarusbington, WC. 20315 3179 NORTH WArxims MEMPHIS, TENNESSEE 38 1 27 (90 1)358-4094 P.O. Box 128 YORKVILLE, TENN(ssr r (901) 643-412.3 38389 September 23, 1980 Honorable Paul A. Volcker Chairman Board of Governors of the Federal Reserve System Washington, D. C. 20551 Dear Mr. Chairman: Enclosed is a copy of the letter I received from a constituent in my district regarding his concerns on the policy of high interest rates. I believe you will find the enclosed self explanatory. I am confident that the arguments of this citizen will be given every consideration that they merit. May I please be provided with information to use in response to Mr. Clinton. Thanking you for your kind and prompt attention and with kindest regards, I am cerely, EJ/cac Enclosure https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 13rownsvi1le Bank September 16, 1980 The Honorable Ed Jones The United States House of Representatives 108 Cannon House Office Building Washington, D. C. 20515 Dear Ed: I am writing you concerning the way the Federal Reserve is handling our interest rates. I do not believe that the sitting up there realize what they are doing to the people small business man and the farmer of our community. It does not make much sense to me to talk about inflation when we are bankrupting the above-mentioned people while inflation is actually being caused by the way the government is spending the money. I think the people of our community are completely fed up with the way this is being handled. I personally feel that it is a grave injustice to be treating the people who are supporting the government this way while the government is taking no action at all to slow down spending to help solve the problem. We have had a Chrysler dealer close, a Chevrolet-Buick dealer close, a Massey-Ferguson dealer close, an Allis-Chalmers dealer close, several small retail businesses close, and quite a few building contractors are in serious trouble with houses they have built for sale. Yet, every time we try to hold our interest rates down to help these people the Federal Reserve runs the rates back up. The working people are scared to death of the government and arc afraid to invest in anything in our community. I am sick and tired of the way this is being handled and would appreciate hearing from you concerning your views. Sincerely JOHN CLINTON President JC:jm The HonoraLle Nancy Landau Kasaebauz United States Senate 20510 77aah1ngton, D.C. Li.,ar Nancy. am writin,3 iu further reponse to your concern ciout u1atioi ot fnmnilvq4tct of the lacctronic Fund Tranufer cial institutions using a 2ranel of automated tcller machinc (2V1 czzs to ,J.ultile accountx of the same type '.ut thet cwit 'the,. account aeccIzed ort the terminal that cannot uniclusay t1cRoulation. recei;it, as reirtad Sezte4Aber 24, the Iloard adoFted an amenamvnt to t' 'lationj -;:ffective itzmediatoly, to exen;-t t,-ene terTnina13 fro this identification rw:uirellent. 7.71e oxceTtion us availeAp for AT;:. that were ordured or 5.4uret;aued efore the tegulatir,n isaued in final form. A co;,:i of the pres.! relaazel on t ulent iu enclosed. I *r,clie.ve that thi reaon7ive tck llf:-2 *.t.- SiPa!4A.Voy;b4, Enclosurc LUB,DJ;pjt (i(v-198) bac; Lynne Sarr blallardi (2) %.1/ Ventical 'tr. 'lso sol:t to Cong. Jeffries (1244). https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis . '. ' • 0 GCnt • •r•' ' t'''N 0• •0 ••. • co /.----7: ,1:04%., ,s,. 4.•‘,1 ,,,, 4-. • :.[FIT •I— i'(;''''' .,....-..• , 1 4.. •• '..r'eo -• :1'4. 'R..•/ •• 4RAL REs‘' •• BOARD OF 50VERN0RS OF 'ME FEDERAL RESERVE SYSTEM WASHINGTON, U. C. 20551 PAUL A. VOLCKER CHAIRMAN October 6, 1980 The Honorable John Glenn United States Senate 201 Superior Avenue Room 104 Cleveland, Ohio 44114 Dear Senator Glenn: Thank you for your letter of September 16, concerning the Federal Reserve System's procedures for processing pro tests filed pursuant to the Com munity Reinvestment Act. In par ticular, you mentioned the processing of the CRA challenge by Ohio Public Interest Campaign ("OPIC") and Citizens to Bring Broadway Bac k ("CBBB"), to the application of National City Corporati on, Cleveland, Ohio, to acquire The Henry County Bank. I assure you that in acting on this application, the Board will base its decisi on on all facts of record, including the comments submitted by OPIC and CBBB. In addition, while I believe the System's present procedures for processing CPA protests are fair, I agree tha t a review of these proced ures could be useful. The System has a continuing interest in imp roving its CPA procedures and, in any such review, will take into consideration its experiences in administering the present pro cedures. In closing, I appreciate you r interest in this matter and your comments relating to Community Reinvestment Act generally. Please let me know if I can provide any further informati on. Sincerely, SiPaul A. bidet SMW:CO:pjt (#V-367) bcc: Federal Reserve Bank/Cleveland Attn: John Davis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. Claude Blair President National City Corporation P.O. Box 5756 Cleveland, Ohio Ms. Sandy Buchanan Ohio Public Interest Campaign 340 Chester-12th Building Cleveland, Ohio 44114 Ms. Weinberg Mrs. Mallardi (2)V S&R Clearing Unit Mr. Dan Liuzzo Citizens to Bring Broadway Back 4947 Broadway Avenue ,t ::. Cleveland, Ohio 44127.'/ . 140W :A. ABRAHAM RISICOPF, CONN., CHAIRMAN M. JACKSON. WASH. THOMAS V. EAGLETON, MO. CHARLES H. PERCY. ILL. JACOB K. JAVITS. N.Y. SAM LAWTON CHILES, ELA. NUNN, GA. TED STEVENS, ALASKA JOHN GLENN, OHIO JIM RASF.FIT, TENN. CHARLES MC C. MATHIAS. JR.. MD. JOHN C. DANFORTH. MO. HENR• Y • WILLIAM DAVID N. Priron. ARK. WILLIAM CARL DAVID LEVIN, MICH. V. ROTH. JR., DEL. S. COIIEH, MAINE DURENBERGER, MINN. RICHARD A. WEGMAN CHIEF COUNSEL AND STAFF DIRECTOR https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Action assigned Mr. Peters PZCI-tifcb Zfafez Zertate COMMITTEE ON GOVERNMENTAL AFFAIRS WASHINGTON. D.C. 20510 September 16, 1980 Board of Governors Federal Reserve System Washington, D.C. 20551 Attention: Mr. Paul Volcker, Chairman Dear Mr. Volcker: During the past month my office has received correspondence from the Ohio Public Interest Campaign and the Citizens to Bring Broadway Back expressing concern about the procedures used in their CPA protest of National City Corporation's application to acquire the Henry County Bank. Also, my Executive Assistant in Cleveland, Mr. Pat Bluso, attended a meeting in the North Broadway neighborhood on September 10, where the case was discussed by OPIC and CRTIR. After talking with Mr. Bluso, I feel that the Federal Reserve Bank of Cleveland has attempted to be fair, but I am concerned that the Federal Reserve System's procedures for CPA are not the most effective possible for adjudicating and mediating such sensitive matters. Since the Community Reinvestment Act is still relatively new, I would like to suggest that a review of procedures might be useful to all parties involved. In reviewing your published procedures, it's clear that the decision on whether to have a formal hearing is made by the Board of Governors rather than Reserve Bank Staff. In making your decision on a hearing in the National City case, I know you will take into consideration the needs and concerns of all parties. Sincerely, John Glenn United States Senator JG:bjp Please reply to Senator John Glenn 201 Superior Avenue Room 104 Cleveland, Ohio 44114 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ........ •9 "i' *. ,.3;-: -Zi`.•::. t:; 11•• •'' ofc01/t EIDARD OF 50VERNORS ,-,-.-1, :o /;•,,i-i!: : :: ,,..1 %. 7 • t: r4)•••••••.,,....,1; 3' O r THE FEDERAL RESERVE SYSTEM 11.ry: 4-... , -4441 • ' -?-4;. ,../ '• ' ..0/:;•-•:-___ 0- • • :'?•41_ WASHINGTON. 0 C 20551 October 7, 1980 PAUL A VOLCKER CHAtR MAN The Honorable Abraham A. Ribicoff Chairman Committee on Governmental Affairs United States Senate Washington, D.C. 20510 Dear Chairman Ribicoff: This letter concerns the General Accounting Office (GAO) Report GGD-80-59 entitled "Internal Auditing Can be Strengthened in the Federal Reserve System." This report contains recommendations concerning the Federal Reserve and therefore requires comment in accordance with Section 236 of the Legislative Reorganization Act of 1970. The GAO report makes three recommendations regarding the Federal Reserve's use of internal auditing: one concerns internal auditing at the Board of Governors; the other two concern internal auditing of the Federal Reserve Banks by the General Auditors. These recommendations do not concern, directly or indirectly, the Federal Reserve System's use of internal auditing with respect to more than 80 percent of its operations. The GAO recommendations are limited because the Federal Reserve System maintains one of the largest internal auditing capabilities in the U.S. Government on both an absolute scale and relative to the size of our budget and staff. This is not mentioned in the GAO report. The observations that are the basis for the three GAO recommendations are directed not at whether the remaining operations are audited, which they are, or at the results of such audits, but only at the specific methods employed. Moreover, there is not unanimous agreement in the auditing profession regarding such methods. Indeed, the Board's external auditors, who have the responsibility to review our overall audit program, have not questioned these methods. The Board addressed the basis for its current internal auditing methods in its May 7, 1980, response to the draft of the GAO report. The Board's response is included in the Appendix to the final report. This letter is meant to supplement that response and identify the actions that the Board has taken and plans to take with regard to the three recommendations. GAO's first recommendation is that the Board "establish a permanent, independent internal audit group at the Board of Governors, consistent with professional internal auditing standards." The GAO basis for this recommendation is their general observation that no single group involved in the Board's auditing function provides fully independent, full scope evaluations. Specifically, GAO observed that the Operational Review Program (ORP), although it reports to the Vice Chairman, is staffed entirely by part-time personnel and, therefore, presents the possibility of compromise of independence; the ORP performs no follow-up on its reviews; the Controller https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis To: The Honorable Abraham A. Ribicoff -2lacks independence since he reports directly to the Staff Director for Management; the possibility for redundancy exists between ORP's and the Controller's efforts; arid the external auditor's activities are limited to financial reviews. If adopted in toto, the GAO recommendations would combine the internal auditing activities of the Controller with the ORP into a single group with direct access to the Board. It is the Board's belief that the present combination of the ORP and the Office of the Controller has served and can continue to serve the needs of the Board well in the areas of operational review and financial controls. A group such as GAO recommends is not absolutely necessary nor even better than the current combination because of the unique nature of the Board's operations for the following reasons. First, the Board's financial operations are expense oriented, and predominantly (80 per cent) made up of personal services expenses; therefore, financial risks are identified almost entirely with the personal services area. All no purchases and services are directed and controlled on-site. The Board issues grants, large scale, off-site contracts, or computer based financial transactions nment (other than payroll), characteristics of the operations of many large gover ized agencies. Therefore, the potential for fraud and abuse is identified, minim e of and controlled adequately by the internal techniques overseen by the Offic the Controller. m Second, in view of the special status of the Federal Reserve Syste l financial in the U.S. Government, the Board has chosen to undergo an annua ments and the examination by an outside auditor who reviews our financial state Board. This status of our internal controls and reports the results directly to the government function is typically assigned to internal auditing groups in other The Board does agencies and often performed on less than an annual frequency. examination or not wish to change the method or frequency of such an supplement it with a redundant internal capability. that of Third, management of the Board's operations is separate from ds only to the the Federal Reserve Banks; its internal auditing function exten ng functions serve Board, unlike other government agencies whose internal auditi general auditors headquarters and regional operations. Separate Board staff and functions of those in each of the Reserve Banks perform the internal auditing Banks and their branches. large and Finally, there exists in the Federal Reserve Banks a with the Federal experienced staff both trained in internal auditing and familiar that, with the proper Reserve's highly technical operations. The Board believes operations can best be precautions, efficiency and effectiveness reviews of its cadre of generalists achieved through the use of such staff rather than a small creation of a separate, permanently assigned to the Board's staff. Although the Board's belief that it permanent staff has a certain superficial appeal, it is the would turn out to be divisive and counterproductive. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis To: The Honorable Abraham A. Ribicoff -3Although the Board is generally satisfied with the organization of its current internal auditing functions, the Board has taken the following actions in the areas of the GAO observations: o Created a full-time position of Manager, Operational Review Activities in the Office of Board Members which will substantially reduce the possibility of independence compromises (recruiting for this position is currently underway); o Directed its Operational Review Committee to reconcile with the Vice Chairman all team-member independence conflicts, should they arise; o Directed the Operational Review Committee to follow up on its reviews, including all those undertaken since the inception of the program; o Reaffirmed the Controller's direct access to the Board in areas involving internal auditing; o Assigned two additional full-time staff members to the Controller's internal auditing function; and o Directed the Chairman of the Operational Review Committee and the Controller to coordinate their activities in the interest of sharing mutually relevant information and avoiding redundant activities. In addition, the Board plans to go beyond the areas covered by the GAO report and in the future will: o Direct the external auditor to review the policies and procedures of the Operational Review Program on a periodic basis and report its results to the Board; and o Assign the responsibility to follow up specifically on actions resulting from GAO recommendations to our internal auditing elements. With regard to the GAO report in the area of internal audit activities at the Reserve Banks, the Board was generally gratified that the report gave recognition to a number of positive features of those activities: its foundation on progressive and dynamic System -wide audit standards, its organizational independence, its provision for a quality control mechanism managed through the Board of Governors, its commitment to building highly qualified professional staffs and, in general, the encouragement and support afforded the audit function by System management. The Board believes Reserve Bank audit departments make valuable observations and recommendations and that they do a thorough job of utilizing modern tools and techniques. • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • S To: The Honorable Abraham A. Ribicoff -4- Among the tools used by audit departments to review operations and to signal potential trouble spots is the System's own expense accounting and management information system. PACS, as our planning and control system is known, was recently cited by the Joint Financial Management Improvement Program, to which the GAO itself has been a collaborating agency, as one of the five most sophisticated of its kind in government. We believe that the nature of the current report recommendations, like the aforementioned evaluation of the System's underlying management information system, suggests that Federal Reserve controls, including audit policies and practices, have measured up well against the stiff criteria that traditionally marks GAO scrutiny. GAO's second recommendation is that the Board "require Reserve Bank General Auditors to review the efficiency and effectiveness of bank supervision and regulation and economic research activities." The Board wishes to reaffirm its general agreement with this recommendation. As noted in the response to the preliminary report, the Board of Governors has issued a policy letter that endorses the appropriateness of Reserve Bank audits of supervision and regulation and economic research. It is believed that this endorsement furnishes Reserve Bank General Auditors with explicit authorization to perform reviews in those staff areas. Furthermore, the Conference of General Auditors, consisting of the General Auditor of each Federal Reserve Bank, has charged a task force with responsibility for developing a "core program" for use by Reserve Bank audit departments in tailoring procedures for their own reviews of supervision and regulation. The "core program" has been completed and forwarded to the Conference of General Auditors for its approval. Also, a task force will be named in the near future to develop similar guidelines for use in performing reviews in the economic research area. While it is believed, then, that significant progress has already been made in developing a collective approach to the audit of staff areas by the General Auditors, the Board continues to believe that the unrestricted scope of The Board believes that the GAO's such audits cannot be justified. recommendation has insufficiently distinguished between the objectives of (1) auditing for efficiency and effectiveness of internal controls and existing operating procedures, and (2) auditing performance against "desired results." The Federal Reserve's missions in the bank supervision and regulation and economic research areas are aimed at broad national goals and objectives toward which other governmental entities are working as well. Success or failure in achieving such "desired results" should only be measured at a level where those performing the evaluation are able to compare the products of all of the contributing units and also consider the impact of external factors. In the Federal Reserve System, the relatively local Reserve Bank internal audit 4 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis To: The Honorable Abraham A. Ribicoff ->departnents do not have the proper vantage point from which to make such an evaluation. Therefore, while the Board fully encourages General Auditors' evaluation of, the efficiency and effectiveness of internal controls and operating procedures, the synergism of the System's component members and the presence of external variables do not permit a meaningful evaluation at the local level of the respective components' professional products and judgments that support the System's overall effectiveness in contributing to broad national goals. The Board believes that an evaluation of the professional products and judgments of the bank supervision and regulation area is currently being performed at the appropriate level. Such an evaluation is afforded on a continuous basis through the Board's Division of Banking Supervision and Regulation, and on a periodic basis via Board-conducted operations review programs. Moreover, the Board of Governors itself maintains a further independent check on the System's supervision and regulation activities through its Committee on Banking Supervision and Regulation, consisting of three Is. memS ers. Finally, the System's overall performance in this area is re • gularly scrutinized by the Congress and its effectiveness weighed against the perceived effectiveness of other financial institution supervisory agencies. Similarly, the Board believes that the "desired results" of the economic research function at the Reserve Banks are already evaluated at appropriately high levels. Since Reserve Bank research activities are primarily aimed at furnishing data and information for judgmental use and consideration by the Board of Governors and the Federal Open Market Committee in formulating national monetary and credit policies, professional evaluations of those activities must be performed by members of those bodies. Such appraisals are currently performed on a continuous basis by the respective Reserve Bank Presidents who, as participants in the deliberations of the FOMC, not only direct the economic research activities of their own Banks but use and must rely on the products of the other Banks. In addition, the Committee on Research and Statistics of the Board of Governors, composed of individuals who can appreciate the full range of national policy considerations as well as the System's regional economic intelligence needs, evaluate the effectiveness of the System's collective and component research capabilities. In the economic research area, as well, Congressional oversight serves to appraise independently the Federal Reserve's effectiveness in the monetary policy area, which is highly related to and I ependent on the research function. In summary then, the Board believes that reviews by Reserve Bank audit departments, keying on compliance, administrative efficiency and effectiveness, and the appropriateness of internal controls and operating procedures, will contribute significantly to the quality and comprehensiveness of broader evaluations that must be made at levels commensurate with those at https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis To: The Honorable Abraham A. Ribicoff -6which policies are actually made and at which ultimate responsibility lies. Thus, while. the GAO regards limitations placed on the scope of such reviews by Reserve Bank audit departments as inconsistent with professional internal auditing standards, the Board believes they are necessary given the decisionmaking structure of the System and the cornplexity and sensitivity of its "desired results." Furthermore, the Board is satisfied that the broader types of evaluations that the GAO envisions be made by internal audit departments are already regularly made at more appropriateI GAO's final recommendation is that the Board "instruct the Conference of General Auditors to amend their 'Audit Standards and Levels of Audit Attention for Federal Reserve Banks' to include a System -wide approach toward reviewing bank supervision and regulation and economic research activities and a specific operational policy statement requiring the follow-up of the Board of Governors' reviews by General Auditors." The Board believes the issuance of its May 12, 1980, policy letter in this regard has the intended effect of requiring such reviews. Furthermore, efforts made by the Conference of General Auditors to design core audit programs for use in the bank supervision and economic research areas evidences the development of a System -wide approach toward reviewing these areas. The core program for supervision and regulation will be presented to the Conference in October 1980 and the core program for research is expected to be completed in 1981. The Conference is also preparing a statement for inclusion in its Audit Standards concerning follow-up of all audits and external reviews for adoption in October. Also, the General Auditors have been officially charged with following up on findings and recommendations resulting from Board of Governors operations reviews since 1975, and the Board clarified and strengthened that requirement last year. In addition, the Board expects the Conference of General Auditors to consider changes to its "Audit Standards" document that would establish a separate standard prescribing responsibilities for following up on the results of all internal and external reviews. Sincerely, VAI:evjj lx:c: Mr. Malrenin :s.allardi (2) Identical letter also sent to Mairman Jack Ilrooks. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis October 7, 1980 Dea/ Henry; I understanS that you are doing very well . It's a uniaue way to spend an election campaign -- maybe better suiteI to a Fed Chairman. But we look forward to seeing you back, hale and hearty as ever. All the best, The Honorable Henry S. Reuss St. Mary's Hospital 2323 North Lake Drive Milwaukee, Wisconsin 53211 CCM;PAV https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis October 7, 1980 Dar Pat: I appreciate your sending me the copy of "Counting Our Blessings." Sometimes I need to be reminded, and I look forward to reading it. Sincerely, The Honorable Daniel P. Moynihan United States Senate Washington, D. C. 20510 CCM • DANIEL PATRICK Moy-NrEIAN UNITED STATES SENATOR https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NEW Youx • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis .. • S BOARD OF GOVEFRNOR5 OFTIIE FEDERAL RESERVE SYSTEM WASHINGTON. D.C. 20551 October 9, 1980 The Honorable Paul E. Tsongas United States Senate Washington, D.C. 20510 Dear Senator Tsongas: Chairman Volcker has asked that I acknowledge receipt of your letter of October 2 requesting views on a letter you received from a constituent expressing concern regarding the activities of Citibank, N.A., New York, New York , in promoting a service called Citi-Shopper. Citi-Shopper is a merchandising service offered to holders of Citibank credit cards by Comp-UCard, Inc., an organization unrelated to Citi bank. Citibank is a national bank and as such is unde r the jurisdiction of the Comptroller of the Curr ency. Citibank's parent corporation, Citicorp, New York, New York , is a bank holding company and its primary supervisory auth ority is the Federal Reserve Board. Members of the Board's staff contacted representatives of Citicorp regarding the Citi-Sho pper program and were advised that the promotional activiti es questioned by your constituent are performed by Citibank rath er than Citicorp. We have, therefore, referred your request to the Comptroller of the Currency for response. Sincerely, (Stnc:!) Donald J. Wina Donald J. Winn Special Assistant to the Board boo; Congressional Liaison Office Office of the Comptroller of the Currency CO:pjt (tV-384) boos Mrs. Mallardi https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis PAUL TSONGAS MASSACHUSETTS "Zfrrifeb fafez Zeltale WASHINGTON. D.C. 20510 October 2, 1980 The Honorable Paul Volcker Chairman Board of Governors of the Federal Reserve System Room B-2125 20th and Constitution Avenue, N.W. Washington, D.C. 20551 Dear Chairman Volcker: I have enclosed a letter from my constituent, Wayne Walega, regarding a Citibank banking service called "Citishopper". Mr. Walega questions whether or not this is a non-related banking service which violates the charter of Citibank. I would appreciate a full report on this matter so I can respond to my constituent. Please answer in duplicate and return the attached materials to the attention of Ms. Toni Travis. Thank you. PAUL E. TSONGAS United States Senator PET/ttt Enclosure 410 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis fl t.!J W4nreJt.1 rilf,N I.VJAWO https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis %#.1,11,mbr 9, ),.notor P,)ul Tsongm!, 2003 .J.F. Kf:nnedy Fedora! building flostr,n, MA 02203 Dar Senator Tsongas, It has recently been announced by Citibank, one of the n ation's laraest banks, that they are -starri ng a new banking service called "Citishopper". It is a telephone buying service, offered in conjunction with Comp -U-Card, Inc. of Stamford, Connecticut; which offers Citibank holders of their VISA and MasterCard, this buyin g service. The cost is based on 118.00 per year membersh ip and it e ntitles the member the right to purchase most small and major appliances among those items listed, at 40% off of the manufacture - s' suggested retail price. This banking service offered to the customers of Citibank for marketing the Visa and MasterCard serv ice is certainly a non -related banking service and must violate the charter o f Citibank. At best, this service does set up an unfair competitive practice for the distributors and retail dealers o f these products. Customers of these buying services are at a disa dvantage insofar as delivered, damaged merchandise is concerned and service to these products when it is required. I would hope that this type of unquestionab le banking service would cause you some concern and that we can look forward to your support in ending these prac tices. Sincerely, c' (: CL .-( V;ayne haleca, CKD President h r./Cr.r C (ti; 7; 7tj:, BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20551 PAUL A. VOLCKER CHAIRMAN October 9, 1980 The Honorable William Proxmire Chairman Committee on Banking, Housing and Urban Affairs United States Senate Washington, D. C. 20510 Dear Chairman Proxmire: In response to your letter of Septembe r 17, the Board's staff has compiled the enclosed material you requested on the issues of remote disbursement and delayed fund s availability. On the subject of remote disbursement , three documents are enclosed: a November 14, 1978, staff memo randum to the Board, the January 11, 1979, press release and poli cy statement issued by the Board, and a May 3, 1978, letter of instructions to Federal Reserve examiners. Regarding delayed funds avai lability, we have enclosed the report of the Delayed Funds Availabi lity Task Force dated February 16, 1979, testimony of Governor Rice before the Commerce, Consumer, and Monetary Affairs Subcommi ttee of the House Committee on Government Operations given on Sept ember 12, 1979, and relevant portions of our response to an inquiry from Chairman Rosenthal of the House Commerce, Consumer, and Monetary Affairs Subcommittee. Not included with this transmittal are copi es of the following material which we have previous ly supplied to you: staff memoranda attached to correspondence on these subjects addressed to you from Chairman Burns dated March 4, 1977, and February 8, 1978, and the 1978 Survey of Selected Bank Prac tices (includes delayed funds availability) conducted by examiner s of the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Federal Reserve System whic h was released by the Board in 1979. Copies of all consumer comp laints and inquiries are being collected from the Reserve Banks as well as being extracted from the Board's files. We expect this mate rial to be available in about two weeks and details of their tran smittal will be arranged with your staff. Board staff work is continuing on efforts to develop recommendations to the Board that could alle viate the undesirable https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • The Honorable William Proxmire Page Two aspects of delayed funds availability and remo te disbursement without imposing burdensome and costly regulation. We will, of course, keep you informed of any action the Board takes regarding either of these issues. Sincerely, Enclosures (OV-368) Lcc.r. heedor https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • 11.rs. Mallardi (2) ff• WILLIAM rproxmiott. %I A. WILLIAMS, JR., NJ. ALAN ERANCTON. CALIF. ADL•I F. STEVENSON. ILL. ROPERT MnRGAN. N.C. DONAL ,W RIEGLE. JR.. MICH. PAUL S. SAIMANES, MD. DON %1.D W STF WART. ALA. WIS., CHAIRMAN JAKE GARN, UTAH JOHN TOWER, TEX. JOHN HEINZ. PA. ion assigned Janet Hart and Bill Wallace for coordination of responfl) o WILLIAM L. ARMSTRONG COLO. NANCY LANDON KASSERAUM, KANS RICHARD G. LUGAR, INO. GEORGE J. MITCHELL. MAINE KENNETH A. MC LEAN. STAFF DIRECTOR N. DANNY WALL, MINORITY STAFr DIRECTOR MARY FRANCES DE LA PAVA, CHIEF CLERK 'ZCItifeb Zfafer. ,Slienate COMMITTEE ON BANKING, HOUSING. AND URBAN AFFAIRS WASHINGTON. D.C. 20510 September 17, 1980 Honorable Paul A. Volcker Chairman Board of Governors of the Federal Reserve System Constitution Avenue between 20th and 21st Streets Washington, D.C. 20551 •-; Dear Chairman Volcker: The Senate Banking Carmittee may schedule oversight hearings at the beginning of the 97th Congress to review the actions taken by the various federal financial regulatory agencies to resolve the issue of delayed funds availability and remote disbursement. To prepare for these hearings, I wish to request copies of all correspondence arising fram and relating to any consumer complaints or inquiries lodged with your agency relating to these issues since January 1, 1977. I understand that it has been the practice of your agency in recent years to forward copies of such camplaints only after the names and addresses of the consumer and the institution have been blacked out, presumably, to preserve the privacy of the consumer. I would request that, henceforth, unexpurgated copies be forwarded in response to this and future requests in view of the fact that consumers will not be identified either in the hearings, the public record or elsewhere without the Committee's staff first acquiring the permission of the consumer involved. I also wish to request copies of any staff survey or study or Board policy statement relating to these areas and developed since January 1, 1977. Sincerel i 1 am Pr Chairman V4P:jqj https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • .• • • . . .• of GOI/t;• BOARD OF GOVERNORS OF THE • • ". • . .... --4 .11t Ft • FEDERAL RESERVE SYSTEM \ 'It.• WASHINGTON — ii'ALRes ••....•• FREDERICK H. SCHULTZ VICE CHAIRMAN October 10, 1980 The Honorable Frank Annunzio Chairman Subcommittee on Consumer Affairs Committee on Banking, Finance and Urban Affairs House of Representatives Washington, D.C. 20515 Dear Chairman Annunzio: In Chairman Volcker's absence, I want to thank you for your letter regarding the Board's proposal to exem pt overdraft checking plans from the Electronic Fund Transfer (EFT) Act's prohibition on compulsory use of EFT as a condition of an extension of credit to a consumer. You believe that adoption of this proposed amen dment to Regulation E would exceed the Board's authority and contravene what you believe to be unambiguous statutory language, and ask that the Board withdraw the proposal. You point out that , under the EFT Act, the Board may grant exceptions for a class of electronic fund transfers only if it concludes that an exception is necessary or proper to effectuate the purposes of the Act, prev ent circumvention or evasion, or facilitate compliance with the stat ute. The primary purpose of the EFT Act (as stated in the statute) is to provide consumers with individual rights with respect to EFT services, and you feel that the Board's proposed exception woul d take from consumers their right not to be coerced into acceptin g EFT services. The Board proposed this amendment in response to petitions from financial institutions. According to the petitioners, the extensive programming changes that would be requ ired in order to eliminate the automatic debiting of minimum paym ents would increase collection and programming costs significantly, and may increase costs for the payments system by leading to grea ter numbers of returned items and Ewer-based payments. The Board is concerned about the adverse impact of regulatory requirements on the provision and cost of EFT services. The EFT Act requires the Board to demonstrate that the consumer protections of Regulation E outweigh the complian ce costs imposed https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis I neWAAJA: (V.37) The Honorable Frank Annunzio Page Two upon consumers and financial instit utions. In this instance, as you point out in your letter, the required use of preauthorized debits to repay overdraft checking extensions of credit is not unduly onerous for consumers. Moreover, these plans have been increasingly popular, with little evidence of consumer problems. The costs of nonautomatic pay ment options, on the other hand, could be substantial and could have an adverse impact on the payments system. They could also lead to higher prices or reduce d service levels for consumers. Thu s, a balancing of the competing concerns of consumers and financ ial institutions may well support the proposed exemption. Thank you again for your views on this matter. The Board will consider them along with those of other interested commenters when the amendment is again brought before it. Sincerely, Frederick H. Schultz LBB:DJW.pjt (#V-376) bcc: Gov. Schultz Lynne Barr Mrs. Mallardi https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis MEM, I ANN] N710, ILL., CHAIRMAN CLADYA NON SrELLMAN, MD. EIRtlry I .17-ENT°. MINN. IWAL, F P E. FAUNTROY. D.C. J. MITCHELL, MD. CUPTIF. 'INS, TOR STAFF DIU • • THOMAS D. EVANS, JR.. DEL. CHALMERS P. WYLIE. OHIO DON RITTER, PA. U.S. HOUSE OF REPRESENTATIVES NINETY-SIX I H CONGRESS SUBCOMMITTEE ON CONSUMER AFFAIRS TELEPH(NF_: 225-9181 OF THE COMMITTEE ON BANKING, FINANCE AND URBAN AFFAIRS ROOM 212 HOUSE OFFICE BUILDING ANNEX WASHINGTON, D.C. 20515 September 29, 1980 Honorable Paul A. Volcker Chairman Federal Reserve Board 20th Street & Constitution Avenue, N.W. Washington, D.C. 20551 Re: Docket No. R-326 Dear Mr. Chairman: I have reviewed the Board's proposed amendment to Regulation E to exempt overdraft checking plans from the Electronic Fund Transfer Act's prohibition against any person conditioning the extension of credit to a consumer on such consumer's repayment by means of preauthorized electronic fund transfers. The impact of permitting preauthorized debits by a financial institution to repay extensions of credit pursuant to an overdraft checking plan is not unduly onerous on consumers. However, the Electronic Fund Transfer Act expressly, without ambiguity, forbids a financial institution from forcing a consumer to agree to repay credit through preauthorized debits from his account. Permitting a financial institution to require a consumer to agree to preauthorized debits from his account as part of an overdraft checking agreement is precisely what the Electronic Fund Transfer law forbids. This provision of the law provides consumers with the right to be protected from being coerced into accepting electronic fund transfer services. I believe the Board is exceeding its regulatory authority by proposing this exemption. Section 904(c) of the Act grants the Board regulatory authority, but limits that authority so that the Board may only grant exceptions for a class of electronic fund transfers if the Board concludes that the exception is necessary or proper to effectuate the purposes of the Electronic Fund Transfer Act, the exception will prevent the circumvention or evasion of the purposes of the Electronic Fund Transfer Act or the exception will facilitate compliance with the purposes of the Electronic Fund Transfer Act. Section 902 of the Electronic Fund Transfer Act sets forth the purpose of the law. It states in relevant part: The primary objective of this title, however, is a provision of individual consumer rights. Since the Board's action will take from consumers the individual consumer right provided in Section 913 that they not be coerced into accepting electronic fund transfer services, the Board's action is in violation of its regulatory authority. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis % .. s e Honorable Paul A. Volcker September 29, 1930 Page Two If the Board feels there is a compelling need to take from consumers a consumer protection clearly provided to them under the Electronic Fund Transfer Act, the appropriate action for the Board to take is to recommend that Congress amend the law so that overdraft checking plans are exempt. The Board, in proposing this exemption as a regulatory amendment is usurping Congressional authority. Accordingly, I believe the Board should withdraw this proposed amendment. I would appreciate an explanation of why the Board chose in this instance to exceed its authority under Section 904(c) of the Electronic Fund Transfer Act. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis I With every best wish, Sincerely, . ,.../.......-7c74 Frank Annunzio Chairman BOARD OF GOVERNORS Of THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20551 PAUL A. VOLCKER CHAIRMAN October 15, 1980 The Honorable Norman D. Dicks House of Representatives Washington, D. C. 20515 Dear Mr. Dicks: Thank you for your letter of October 3 regarding the Federal Reserve's conduct of monetary policy. The Board share s your concern about the problems facing the economy and about the relatively harsh impacts of high interest rates on some sectors, such as housing. However, we believe that the way out of the present difficulties is not to be found in a rollback of recent increases in the discount rate or in an attempt to push inter est rates down to lower levels. This is not to say that it is the aim of the Federal Reserve to maintain a high level of interest rates. Rathe r we are endeavoring to pursue a long-range policy that will help restore price stability and foster an environment condu cive to sustained, vigorous economic growth. It is well-establish ed that price stability cannot be attained if money is permitted to expand too rapidly. Consequently, we have set out to achie ve a gradual moderation of monetary expansion. Unfortunately, in the recent period demands for money and credit have been enlar ged as the continuing brisk rise in the general level of price s, occurring against a backdrop of firming business activity, has resulted in pressures on financial markets and increasing rates. Those tendencies for rates to rise perhaps could have been offset for a time, but only by permitting a still more rapid growth of money and credit, with clearly adverse results with respe ct to inflation in the months ahead. The fact of the matter is that we cannot hope to have a substantial and durable drop in interest rates until there is a decisive slowing in the pace of inflation and a lowering of the inflationary expectations that are currently embedded in rates. You suggest that the Federal Reserve might be able to achieve its basic objectives at lower interest rates through the use of selective credit controls. The System has only a https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The Honorable Norman D. Dicks Page Two very limited set of selective con trol measures at its disposal, primarily the power to set margin requirements on certain security transactions. The extraordinary pow ers granted to the Federal Reserve by the President under the Credit Control Act earlier this yoar have been revoked--as the y should have been once it became clear: that the inflationary pressu res in the economy were not being supported by excessive use of cre dit by businesses or consumers . T think it fair to say that our experience with the special cre dit restraints served to reinforce the view that credit controls are extremely difficult to operate in a way that is equitable and tha t avoids undesirable distortions of funds flows. In most circumstances, our highly competitive financial system can be expected to bring about a more efficient allocation of credit among the many potential borrowers in our economy than can any governmental agency. I share your belief that our abi lity to achieve strong, non-inflationary economic growth would be enhanced by a restructuring of our tax system that pro vided greater incentives for business investment. With the potential after-tax returns on capital outlays improved by a mor e hospitable tax structure, firms would be in a position to bid more aggressively for funds in the nation's capital markets. The most urgent priority for fed eral tax policy, as for monetary policy, is to exercise the sustained restraint necessary to wind down the inflation that is plaguing the economy. Restoration of reasonable price stability would in itself produce conditions more conducive to saving and long-term investment. My colleagues and I on the Board believe that the decision by the Congress to defer action on tax cut proposals was a most constructive step in the fight agains t inflation, and continued fiscal discipline will do much to ease the burden of needed monetary restraint. In these difficult times no one can be certain of the precise answer to the problems confronting us. I hope that the ongoing dialogue between member s of the Congress and this Board will aid in the identification and implementation of effective public policy action. Sincerely, S/Paul A, VolQ_ket MJP:JZ:vcd (V-381) bcc: Mr. Kichline Mr. Zeisel Mr. Prell Mrs. Mallardi (2)10"°. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NORMAN D. DICKS • 6TH '.DISTRICT, WASHINGTON • • DISTRICT OFFICES: PIERCE COUNTY SUITE 602 SECURITY BUILDING COMMITTEE. 2 PACIFIC AVENUE 1 915/ APPROPRIATIONS TACOMA, WASHINGTON 98402 PHONE:(206) 593-6536 SUBCOMMITTEES. DEFENSE KITSAP COUNTY INTERIOR SUITE 3 Congre55 of the Eittiteb tatc 1508 LONGWORTH HOUSE OFFICE BUILDING WASHINGTON, D.C. 20515 PHONE:(202) 225-5916 900 PACIFIC AVENUE BREmERTON, WASHINGTON 98310 PHONE:(206) 479-4011 3i)ouie of leprefkntatibesS SOUTH KING COUNTY SUITE 101 EVagbington, 39.e. 20515 / 1025 Sotrn4 320TH FEDERAL WAY, WASHINGTON 98003 PHONE:(206) 941-2382 October 3, 1980 Chairman Paul A. Volcker Board of Governors Federal Reserve Board 20th and Constitution Avenue, NW Washington, D.C. 20551 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Dear Mr. Chairman: to immediately At this time, I urge you and the Federal Reserve Board ne other alternatives roll back the July increases in the discount rate and exami unnecessary to eliminate the rate of inflation without causing additional hardship to the American people. to In my view, the current high discount rates will ultimately prove nation's be extremely counter-productive to our efforts to restore this economic health. t The Federal Reserve's high interest policy has had a devastating effec interest rates, on America's housing industry. Because of the recent high This has caused housing starts are down an astounding 34 percent from last year. prevented thousands large numbersof homebuilders to absorb severe business losses, cannot continue. of hcmebuyers from buying homes and harmed our realtors. This , I As I told you and the President this spring at the White House est rate am very concerned that the continuation of the Board's high inter essarily policy will lengthen the current recession and continue the unnec ands thous high levels of unemployment which exist. This policy has caused on the of Americans to suffer needlessly and has created severe pressures rises by budget. As I am sure you know, when unemployment in this country al government one percentage point annually, it autamatically costs the Feder billions in lost tax revenues. There are alternatives to high interest rates which can be used to tive slow inflation. For instance, the Federal Reserve can use its selec investments credit control authority to direct available capital into long-term manufactured which will increase current supplies of housing, energy, and other goods. All of these alternatives should be explored immediately. • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Chairman Paul A. Volcker Page Two October 3, 1980 I am convinced that these alternatives, when coMbined with Congression ase efforts to develop "supply-side" economic and tax proposals to incre economic health our nation's productivity, can effectively restore America's and substantially reduce the current rate of inflation. Thank you for your kind consideration of this matter. Sincerely, NORMAN D. DICKS Member of Congress NDD:wp UNITED STATES SENATE WASHINGTON, D. C. HOWARD H. BAKER,JR. TENNESSEE October 1, 1980 The Honorable Paul A. Volcker Chairman Board of Governors of the Federal Reserve System Washington, D.C. 20551 Dear Paul: Thank you for sending to me a copy of your letter to Senator Byrd on the advisability of a pre-election tax cut. Since 6iw J ward H. L' HHBJr:rdt https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20 551 PAUL A. VOLCKER CHAIRMAN October 15, 1980 The Honorable Dante B. Fascell House of Representatives Washington, D.C. 20515 Dear Mr. Fascell: Thank you for your note of October 2 requ esting comment on correspondence you received from Mr. Robert L. Epling, President of the Community Bank of Homestead. Mr. Epling expresses concern about what he beli eves to be an unfair application by the courts of the Truth in Lending law's civil liability provisions. He is particul arly concerned about court interpretations of the regulation holding that the right of a creditor, in an automobile installment sale contract, to receive insurance proceeds and retain unearned insu rance premiums constitutes a security interest that must be disclose d. Based on these court decisions, financial institutions have been held liable for a statutory penalty of $1,000 per obligor in cases where the disclosure appeared on the reverse rather than the face of the contract. The Board is aware of the difficulties that creditors face in achieving compliance with Truth in Lend ing disclosure requirements. The requirements relating to the disclosu re of security interests have been particularly troublesome. The staff is now restudying the relevant provisions of Regulation Z, following the adoption of the Truth in Lending Simplification and Reform Act, in the light of public comments on this issue. We believe the revised regulation that is ultimately adopted by the Board will provide clearer guidance to creditors--and to the courts-regarding disclosures, and will thereby alleviate some of the burden that creditors now face in their efforts to comply. The prom ulgation by the Board of model disclosure forms (pursuant to a stat utory mandate) should also enhance understanding and compliance, and provide a safe harbor from civil liability. Application of the Act's civil liability prov isions, however, is totally within the province of the cour ts. The recent statutory amendments, as you may know, do attempt to narr ow the scope of creditors' liability by reducing the number of disclosures that https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • The Honorable Dante B. Fascell Page Two are subject to the statutory penalty. It is hoped that this change will eliminate litigation such as that described by Mr. Epling, which is based on violations of a pur ely technical nature. I hope this response will be helpful. if we can be of further assistance. Please let me know Sincerely, RS:COlvjt (#1 .:.vo 1 ; https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis V-380) Ex. Silver :Arse vallardi (20 a ction assignei Janet H.....,-.ES axt R. o REG A PI DANTE R. FASCEll 41110 I5!,1DO,TRUCT.RtHrolI ADMiNISTIAtin ASSIST commqvrts• FOREIG4 AFFAIRS cHAtpt.fati mir•siatitriAl OPERATIONI SoperilleTTIE MUM* 1.1Tti IMCIIICAM Ar7AIR1 SUICOMMITTft GOVERNMENT OrERATIONS conart51 of tfie ?Unita; tatt pottle of ileprosentatiticti MASbingtott. D.C. 20515 INIMOIR: MISLATPOPI 4WD ORTIONAL Ifetilat S.'SCOMMITTUE COMMISSICN ON SICUNITY AND COOPERATION IN Lul:-PE October 2, 1980 cHA,RMAN CANADIAN—UNITED STATES INT ERPARLIAMENTARY GROUP CHAIRMAN, U.S. DELEGATION The Honorable Paul A. Volcker Chairman, Federal Reserve Board 20th Street & Constitution, N.W. 20551 Washington, D.C. Dear Mr. Chairman: Enclosed is a copy of correspondence from my constituent, Mr. Robert Epling. Your consideration and comments regarding the matter discussed in his correspondence would be greatly appreciated. Sincerely, a, DANTE B. FASCELL Member of Congress DBF/AAC Enclosure https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis COIY1MONIT BANK • OF HOMESTEAD MI . September 10, 1980 , 7 Paul A. Volcker, -Chairman Federal Reserve Board Federal Reserve Building St. Constitution Ave. & 20 Washington, D. C. 20551 RE: -Lending Act Alleged Violations of Truth-In Dear Mr. Volcker: r attention which appears to you to nt ide inc an ng bri to We should like A. tion 128(a)(10), 15 U.S.C. Sec of on ati lic app or on ati be an unfair interpret n Z,. Section ding Regulations; Regulatio Len InthTru 0); )(1 8(a 163 Section A. following Section 1700. 226.8(b), (b)(5), 15 U.S.C. Retail k of Homestead purchased a Ban ity mun Com 9, 197 21, On September of Homestead. The borrower's . Inc es, Sal Car s Cy' m Instalment Contract fro is enclosed. The os. A copy of the contract Ram ia Mar and on Ram e wer names n, and the ner with adequate documentatio man mal nor a in d dle han loan was tract. ts in accordance with the con men pay all e mad e dat to IK)rrower has dence from received a copy of correspon we 0, 198 17, May ut abo On or Inc. Florida Rural Legal Services, the h wit ey orn att an d, Robert M. Hustea and is self-explanatory. A copy of same is enclosed the reverse correspondence is untrue, as the in n tio usa acc st fir The or to include the right of the credit s doe ) ted igh ghl (hi ct tra of the con m cancelled insurance policies. retain returned premiums fro ce been of the correspondence have sin ns tio usa acc rd thi and The seccnd by orrect and properly disclosed inc n bee e hav to d tea Hus acknowledged by Mr. the bank. ies, 551 F.2d ions in Davis v. United Compan Rased upon similar situat it was v. Allen-Russel Ford, 78-1072, son ond Edm and 7) 197 ., Cir 971 (5th ons were liable for a statutory uti tit ins ing anc fin the t tha adjudicated e of the disclosure was on the revers e aus bec er mak per 000 $1, penalty of tract. (See enclosures from con the of e fac the n tha her the contract rat FEDERAL REPORTER). ionale is case have been harmed and our rat None of the parties in our y for the k must pay this statutory penalt ban our t tha t fac the to absent tract. closure on the "face" of the con dis the ing hav not of e lur simple fai ing iously add to the cost of borrow obv l wil ies alt pen h suc of Our payment for all consumers. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis RIDA 33030 POST OFFICE ROX 379, HOMESTEAD, FLO (305)245-2211 4 September 10, 1980 aul A. Volcker, Chairman 'Pare Two and we do not feel Many fellow bankers have similar liabilities to suffer from the statute. it was the "legislative intent" for business fair and equitable We at Community Bank pride ourselves in being th; doing our best to obey bankers as evidenced by our earnings and grow y violate the law. the law. We certainly would not intentionall erely request your In view of the situation presented, we sinc to remedy the situation. consideration of leaislation or regulations Very truly yours, L. En?,' President RLE:jn cc: https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Senator Lawton Chiles Senator Richard Stone Congressman Dante Fascell Senator Dick Anderson Mr. G. Eicher Mr. J. McDonald Mr. J. Marcus Mr. D. Stone ion Mr. J. Milstead-Florida Bankers Associat American Bankers Association - Atlanta Federal Deposit Insurance Corporation State Comptroller of Banking : Florida Rural Legal Services, Inc. and • Legal Services of Greater Miami, Inc. 381 NORTH KROME AVENUE, SUITE 204 POST OFFICE BOX P HOMESTEAD, FLORIDA 33030 TELEPHONE:(305) 248-5500 nay 15, 1980 Cy's Car Sales 29120 South Fecleral Highway Homestead, Florida 33030 Dear nr. Pastor: On September 21, 1979 you sold to Ramon and Maria Ramos a 1976 Ford Torino. The contract form used violates the Truth in Lendina Act in the following ways. First, the description of the security interest does not include the richt of the creditor to retain returned premiums from cancelled insurance policies. Edmondson v AllenRussell Ford, 577 F.2d 291 (5th Cir., 1978). Nor does it -disclose the reauirement of physical damage insurance being maintained nor that such insurance is payable to the creditor. 011, Second, the default charges are not properly disclosed in that your perlineation of a portion of that disclosure renders it inconsistent with permissible charges under law. I hereby make demand on you for the sum of $1,000.00 for each buyer for the faulty disclosures, as provided by the Truth In Lending Act. see Davis v United Companies, 551 F.2d 971(5th Cir., 1977). This demand is also directed to Community Bank of Homestead, to whom I am providing a copy of this letter. The case citations are supplied as a courtesy so that legal correctness of our position can be checked by your or the b'ank's attorney with the utmost economy and I suggest that you have an attorney read the cases cited; if 'we get into litigation and our position prove correct, you will be liable for attorneys fees to Plaintiffs' counsel. I hope that we can all save expense and aggravation by settling immediately. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Very truly yours, Robert M. Hustead Attorney At Law r_: On- Removal Notice The item(s) identified below have been removed in accordance with FRASER's policy on handling sensitive information in digitization projects due to personally identifiable information. Citation Information Document Type: Sale contract Citations: Number of Pages Removed: 2 Sale contract, Cy's Car Sales, Inc., September 21, 1979. Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org • JOINT LAW OFFICES OF Florida Itural Legal Services, Inc. 1.1-1(1 Legal Services of Greater Miami, Inc. 381 NORTH KROME AVENUE, SUITE 204 POST OFFICE BOX P HOMESTEAD, FLORIDA 33030 TELEPHONE:(305) 248-5500 July 14, 1980 Dennis E. Stone, Esq. Malikas & Stone Krome Plaza, Suite 868 9th and North Krome Avenue Homestead, Florida 33030 Dear Mr. Stone: Please find enclosed the copies of the The United _ States Law Week entries on Edmondson v. Allen Russel , }ord. The first page is the subject matter summary of cases recently filed and the second reflects the denial of certiorari by the Supreme Court. While I knew that I had read that cert had been denied, I was way off on the date; the denial appears in the May 15, 1979, issue of U.S. Law Week. I hope that this information results in some expeditious resolution of our case. With best regards, I remain Vei.V truly youys, / ) I- Rob rt M. Hustead RNH/rs/enc. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Removal Notice The item(s) identified below have been removed in accordance with FRASER's policy on handling sensitive information in digitization projects due to copyright protections. Citation Information Document Type: Newspaper articles Citations: Number of Pages Removed: 14 "78-1072 Ford Motor Credit Co. v. Edmondson." United States Law Week, 1979. "Money and Finance." United States Law Week, 1979. "Edmondson v. Allen-Russell Ford, Inc." Federal Reporter 2d Series, 1979. Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20551 PAUL A. VOLCKER CHAIRMAN October 15, 1980 The Honorable Abraham A. Ribicoff Chairman Committee on Governmental Affairs United States Senate Washington, D.C. 20510 Re: Report by the General Accounting Office entitled "Despite Positive Effects, Further For eign Acquisitions of U.S. Banks Should Be Limited Until Policy Conflicts Are Fully Addressed" (GG D-80-66) Dear Chairman Ribicoff: On pages 5-14 of this report, certai n recommendations are directed to the Board and to the other Federal banking agencies. These recommendations concern the procedures followed and the information received when applications are received for foreign acquisitions of U.S. banks. The first of the three recommend ations is that, in such circumstances, contact be made with the regulatory authority of the acquiring bank to determine the bank's financial strength and reputation. As noted in the Board's earlier comment on the draft of this report, the Board announced in its policy statement dated February 23, 1979, that it would obt ain the views of the home regulatory authority before acting on an application by a foreign bank to acquire a U.S. bank. The second recommendation is tha t the Board deny applications where the home regulatory aut hority furnishes an unfavorable reference. Under the Bank Holding Company Act, the Board is obliged to take into consideration, among other things, the financial and managerial resources of the banks con cerned. An adverse comment by the home regulatory authority wou ld reflect unfavorably on the bank's financial and manageria l resources and would be weighed accordingly by the Board in acting on the application. Under the third recommendation, for eign banks and other businesses seeking to acquire U.S. ban ks would have to submit certified consolidated financial statements prepared in accordance with U.S. generally accepted acc ounting pripciples. In the major https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The Honorable Abraham A. Ribico ff Page Two acquisitions that the Board has already acted upon, the Boa rd considered very carefully its nee ds for adequate information on the condition of the acquiring bank. In all of these cases, the Boa rd was able to assure itself abo ut the financial condition of the acquiring bank on the basis of the financial statements presen ted and other information furnis hed, including explanations of any material differences from U.S . accounting standards. It was the Board's judgment that it wou ld be unduly burdensome to req uire the foreign bank to recast all of its accounts, and all of the accounts of its subsidiaries, according to U.S. accounting principle s. The Board continues to believe that the reporting and other inf ormational requirements which it is puttin g in place will be sufficien t for the exercise of its superviso ry responsibilities toward for eign banks. Sincerely, 0d. Waal A.191, irlesidt boob reed &XS, Piallawit(21 Identiatil Utter OA, seat to Chows Jai* UMke• https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis vir LQnoraUe Sas S. aall. Jr. cAous4, lw,romertativas WAahiagton. V.C. 20515 Lter :41r. Sall Than), 4 Ju for your lettur of October 6, 1,00t 00A *WalinV the relortinl protlem under tNe Monetary Control Act 414 196C raised ty jr. T.E. Crawford of the Renderson Claq Prodt Credit Cnion. 11:e aoard has made an effnrt to Amin's. ri .ortirfy burdens on small inetitutions Ly deferrir•:,; reorting and re't,t requirements for those delvsitory inatitutlpn9 vitIn Use than $1 million in total delGaitz (including overN11,000 credit unions) until .ray 1581, and ky reluirinq reports from ecnxisitory Motttuticat. Llztwaen $1 million and $5 stallion Jr. t,r,tAl deposits only (24exter1i LoOntirci in January 1,81. r. Crawcrd has keen cwItacted by staff at the rederal reserve Dank of Ls.114a in an effort to verify the eliqibility-of--' the Lc,”dersen Clay Products Credit Union for deforred reportinl and ItAiilturiaftC4 tof required reservts. Please, lut iae know if I can c of further assistance. ItiAcor.47, wRJ.JSZtCO:pjt (IV-383) Mr. Kichline Lr. Jones Mrs. nallardi (2)%/- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis S/Paul A. Vo!chett Action assigned Mr. Kichline SAM B. HALL. JR. 1 4" • FIRST DISTRICT STATE OF TEXAS COMMITTEES: ;$ JUDICIARY Congrels5 of tfie ifiniteb iptate5 sumommITTrES CRIMINAL JUSTICE IMMIGRATION. CITIZENSHIP, AND INTERNATIONAL LAW SUFICOMMITYL I COMPENSATION, PENSION AND INSURANCE MEDICAL FACILITIES AND BENEFITS U.S. FEDERAL BUILDING. Room G 15 MARSHALL. TEXAS 75670 Pouge of Aepregentatibeti tZlaMjington,;le. 20515 VETERANS AFFAIRS 318 CANNON HousE OrricE BUILDING WASHINGTON. D.C. 20515 TELEPHONE:(202) U.S. POST OFFICE AND FEDERAL BUILDING Room Vil>"-PARIS. TEXAS 754160 October 6, 1980 U.S. POST OFFICE AND FEDERAL BUILDING Room 401--TOCARK ANA. TEXAS 75501 poisoopumw The Honorable Paul A. Volcker, Chairman Board of Governors of the Federal Reserve System Twentieth St. and Constitution Ave. NW Washington, D.C. 20551 Dear Mr. Chairman: Enclosed for your kind attention is a letter from one of my constituents, Mr. T. F. Crawford of Henderson, Texas. As you will note, Mr. Crawford is President of a small credit union which is experiencing difficulties in complying with the reporting requirements created by the Board under the Monetary Control Act of 1980, PL 96-221. While I recognize that this law gives the Board very broad powers in this area, I would encourage reconsideration of the problems many smaller institutions may face in trying to comply with the Boards rules. Any information or advice which you can properly provide concerning this matter will be greatly appreciated, but I would urge an amendment to these reporting requirements to exempt smaller institutions such as Mr. Crawford's be https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Thank you for your assistance and with kindest regards and wishes, I am Sincerely yours, 1.4AAJ ,J47 /gam R. Hall, • • • •" ato. HUST or VICE 11.1x 1129 • HENDERSON, FIX AS 7S652 Septembcr HnnnrNhie SIM B. Hall Jr. House of Representatives 31g Cannon House Office Building Washington, D. C. 20515 Dear Representative Hall: Reference is made to "Ihe Monetary Control Act of 1980" (11 .1.. 96-221), enacted on March 31, 1980. The employees of Henderson Clay Products have a small State Chartered Credit Union with less than .?- 00,000 in shares. This small Credit Union has one part time paid bookkeeper while the remai nder of the Credit Union officers donate their time. NI- purpo se is to encourage thrift among emnloyees and also provide a place where employees can borrow money. Many of our rinority employees find this is the only source of money at reasonable interest rates. The attached publication slal,'s reporting for institutions with deposits less than Si million do not have to report until May 1981; however, the Federal Pseserve Pank of Dallas Circular No. 80-1 71, September 8, 1980 requ i rc a "questionnaire" be completed by September 17, 1980. Ihis questionnaire wonld require several days resea rch Ti order to complete. Additionally, this Credit Union has started to receive volumes of regulations from the Federal Reser ve Bank that are difficult for non-financial personnel to understand . Please help this, as well as other, small Credit Unions escap e the reporting requirements imposed under "The Monetary Contr ol Act of 1980." Most small Credit Unions will not be able to survive government reporting, where as, larger Credit Unions with their full time stalls and larger deposits will find the reporting expensive and tiMe COT1SUMi ng hut achievable. Your assistance is appreciated. Sincer,ely, T. Crawford President TFC/gg enclosure https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis October 1E, 1'380 Thw 4‹,norati1e Portland J. St Cermain Cnairman Cubcomittee on Financial InstitutIns 'Lui-crvisioni Regulation and Inpurarce CoAmitteo on banking, Finance in41, Uran Main; P31106 of Rei.rasentativcs 20515 WaOinton, D.C. 1:?ear Chairman St Cemain, Thank iou for -our letter of Cotocr JoGept. Cwiini as a ii4,1111ter of the Uoard's Cc,nitur 7‘,=INIIry Council. Cugini'a resume i:: on file with t,F, Board, ;trii. I can asure you that his qualifications will roceive full consileration when the Board makes the 1961 aprointments to the Council. we will be in touch wit)' you whon the selections are made. :e :Tird in4rociates reccivir,i ,our recommendation and Jour interest in the Contumer Advisory Counc51. rincerely, sira,. trAcittl: CO.pjt (4V-391) bcc Ann Marie gray (w/foj;le. of inconin) Mallardi (2) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • FAANK ANNUNZIO. ILL. JAMES M HANLEY, N.Y. CARROLL HUBBARD, JR., KY. JERRY M. PATTERSON. CALIF. THOMAS L. ASHLEY, OHIO NORMAN E. D AMOURS. N.H. JOHN J. CAVANAUGH. NEBR. JIM MATTOX, TEX. JOSEPH G. MINISH, N.J. WALTER E. FAUNTROY. D.C. DOUG BARNARD GA. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ,ii Res FER'1AND J. ST ornmioN. R.I., CHAIRMAN o nse will be prepare-1 by Cong. _,iaison Office CHALMERS P. WYLIE. OHIO HENRY J. HYDE. ILL. GEORGE HANSEN, IDAHO U.S. HOUSE OF REPRESENTATIVES JIM LEACH. IOWA CARROLL A. CAMPBELL, JP... S.C. ED BETHUNE. ARK. SUBCOMNITTEEONFINANCIALINSTITUTIONS SUPERVISION, REGULATION AND INSURANCE OF THE COMMITTEE ON BANKING. FINANCE AND URBAN AFFAIRS 4 NINETY-SIXTH CONGRESS WASHINGTON, D.C. 20515 October 10, 1980 Honorable Paul Volcker Chairman Board of Governors of the Federal Reserve System washingLon, D.C. Dear Mr. Chairman: As Chairman of the House Subcommittee on Financial Institutions, I am enthusiastically recommending the appointment of Mr. Joseph Cugini of Rhode Island to be a member of the Consumer Advisory Council of the Federal Reserve System. Mr. Cugini's many years of experience in the credit union movement assures thoughtful and valuable input from the perspective of both financial institutions and the consumers they serve. I am personally acquainted with Mr. Cugini and consider him exceptionally well qualified to serve the Board as a member of the Council. I am certain that his contributions to the work of the Council will reflect his interest in and knowledge of consumer affairs legislation and regulation, as well as his expertise as a credit union manager. I enthusiastically support Mr. Cugini's nomination and urge the Board to appoint him a member of the Consumer Advisory Council of the Federal Reserve System. FJStG:hh 04:144/1.4 BOARD OF GOVERNOR5 OF THE FEDERAL RESERVE SYSTEM WASHINGTON. O. C. 20551 RAL RE-S.• • •.. • • October 17, 1980 The Honorable Berkley Bedell House of Representatives Washington, D.C. 20515 Dear Mr. Bedell: Chairman Volcker has asked me to acknowledge your letter of October 14 requesting our views on a letter you received from Mr. Dick Krommenhoek. Mr. Krommenhoek expresses concern regarding the activities of Citibank, N.A., New York, New York, in promoting a service called Citi-Shopper. Citi-Shopper is a merchandising service offered to holders of Citibank credit cards by Comp-U-Card, Inc., an organization unrelated to Citibank. Citibank is a national bank and as such is under the jurisdiction of the Comptroller of the Currency. Citibank's parent corporation, Citicorp, New York, New York, is a bank holding company and its primary supervisory authority is the Fede ral Reserve Board. Members of the Board's staff contacted representa tives of Citicorp regarding the Citi-Shopper program and were advised that the promotional activities questioned by Mr. Krommenhoe k are performed by Citibank rather than Citicorp. We have, ther efore, referred your request to the Comptroller of the Currency for respo nse. Sincerely, (Signed) Donald I. Winn Donald J. Winn Special Assistant to the Board bcc; Congressional Liaison Office of tho Comptrollar of the Currency COsplt ($V-394) boa; tire. Mallordi‘,/ https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis S BERKLEY DEDELL 6Tti DiTicT. IOWA esponse will be handled by Coressional Liaison wAcKINGTou (wrier Office 405 CANNON 1-10t/SE OrrICE BUILDING 20515 WASHINGTON. D C (202) 225-5476 CONINIITTErn• AGRICULTURE wiinrOmmiTTtrn Congtt5c.") of tijc Uniteb *tates' LIVESTOCK AND GRAINS FAMILY FARMS. RURAL DEvELopmENT AND SPECIAL STUDIES 31)oirst of iitpre5entatibe.5 CONFRvATION AND CREDIT I1MAL 1.11JSINCS5 Z.Zlasbington, n.c. 20315 .1.111CommiT1C1 S October 14, 1980 ANTIT RUST AND RESTRAINT OF TRADE ACTivi riLS AFFECTING SMALL oUSINEsS DISTRICT Orr ICES: 479 FrOCRAL BUILDING FORT DODGE. low* 50501 (515) 573-7169 311 FEDrpe AI_ BuiLoING Stoux C,rv, tow.. (712) 152-4164 51101 EXT. 281 Mr. Paul A. Volcker, Chairman Federal Reserve Board Washington, D.C. 20551 Dear Mr. Volcker: Congressman Bedell has asked that I write to you in regard to a letter he received concerning a new banking service called "Citishopper". A copy of that letter is enclosed. Congressman Bedell 's constituent is concerned that the new service will set up an unfair competitive practice for the distributors and retail dealers of products offered in conjunction with this service. Furthermore, he believes this to be a non-related banking service in violation of the charter of the bank involved. Congressman Bedell believes that these concerns merit review. He would appreciate your consideration of these views, and looks forward to your thoughts on this matter. Thank you for your assistance. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Sincerely, Ga y Hubbard L gislative Assistant to Congressman Bedell rup, 114111." , 0 N.+ 411 4 I, _ 411 KITCHENS by KROMMENHOEK 1916 PIERCE - SIOUX CITY. P. IOWA 51104 • (712) 252.4402 'RECOVED SEP 17 NBC! Dear Representative Bedell, UP 2 2 1380 It has recently been announced by Citibank, one of the nation's largest banks, that they are starting a new banking serv ice called "Citishopper". It is a telephone buying serv ice, offered in conjunction with Comp-U-Card, Inc., of Stamford, Connecticut; which offers Citibank holders of their VISA and Mast erCard, this buying service. The cost is based on $18.00 por year membership and it entitles the member the right to purchase most small and major aopliances among those items listed, at 40% off of the manu facturers' suggested retail price. This banking service offered to the customers of Citibank for marketing the VISA and MasterCard service is certainly a non -related banking service and must violate the charter of the Citibank. At best, this service does set up an unfair competitive practice for the distributors and retail dealers of these products. Customers of these buying services are at a disadvantage insofar as delivered, damaged merchandise is concerned and serv ice to these products when it is required. I would hope that this type of unquestionable banking service would cause you some concern and that we can look forward to your support in ending these practices. Sincerely, // Dick Krommenhoek Kitchens by Krommenhoek 164 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Octolier 1C, 198C The Nonoralle Gary Hart United Stater Senate :.:4Ilhinuton, D.C. 20510 rear Senator Tart. Chaiman Volaer !tar; anYed mc to acl.nowledge your letter of Cctober 10 re9uest1nj our views on a letter you received from r. rarula E. VrA,ir, Jr. rr. Vabie extresnes concern regarainq the cctivitica of Citilank, N.A., nPW York, Vew York, in promoting a acrvice called Citi-Shopper. Citi-Shoppor in a merchandising service offered to holders of Citibank cretlit cards by Comp-U-Card, Inc., an orejanizatien unrelated to Citi)-ank. Citibank in a net:lona' ard Ag such is under the jurisdiction of tno Ccmi'troller of the Currency. Citibank's 1.arent corratio:', Citicorp, New York, New York, is a 1-.ank holding comyany and its I- ririary cu}ervisory authority is the Federal reserve Loard, nembers of the Poard's staff contacted rerrosentatives of Citicorv reyardirvl tLe Citi Shorver pro7ram and were advised that the rromotioral activities itientioned by Vr. 'inbie are performed Uy Citil:ank rather tan Citicorp. Wn hnve, therefore, referred your reuent to the Comptroller of the Currency for resronse. Sincerely, {Sirnstf) Donald I wtiñi nornlei J. Winn Ficcial Annistant to the Iloard bcc; Conuressional Liaison Office Office of the Comvtroller of the Currency CO:ljt (#V-389) Lcc: Mrs. Mallardi 1/ https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis WEIMMMIIMMIMML. GARY HART coLon,A2o https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Repowill be handled by Cong. ',jai* Office COMMITTEES: ARMED SERVICES ENVIRONMENT AND PUBLIC WORKS ?JCnifeb Ztale,c; Zenate BUDGET WASHINGTON, D.C. 20510 October 10, 1980 • The Honorable Paul A. Volcker Chairman of the Board of Governors of the Federal Reserve System 20th and Constitution Avenue, NW Washington, DC 20551 Dear Mr. Chairman: CA) Attached is a copy of a letter from Mr. Harold E. Mabie, Jr. concerning the "citisho pper" service offered by Citibank. The service apparent ly offers appliances at reduced rates to Comp -U-Card, Visa, and Master Charge holders. I would appreciate your attention and review of this matter. Sincerely, 70. Gay Ha Enclosure THIS STATIONERY PRINTED ON PAPER MADE WITH RECYCLED FIBERS 7 i r I F.! 20, S,nator Gary Hart 254 Russell Building Washington, D. C. 20510 Dear Senator Eart: It hqs recently been announced by Citibank, one of the nation's larFost banks, that they are starting a new banking service called "Citishopper". It is a telephone buying service, offered in conjunction with Crnm-U-Card, Inc., of Stamford, Connecticut; which offers Citibnk holders of their Visa and MasterCard, this buying S ervice. The cost is based on $18.00 per year membership and it entitles the r=ber the rirht -to purchas most =all and major appliances amen: those items listed at 405 off the mriurcturers' suggested retail ;-1 • _ ,i(,..:._ tiL iiiie charLt., ...r. ol -Lne .. . .. '011d mu,_-, ,- , vii_a. , - 1. . . , _ ___ . t.,...... I. ..._,..... e dirihutc,rc pnd retail dealers of these products.. . t cf • r-- Customers of thse buying services are at a disadvantage insofar as delivered, damaged merchandise is concerned and service to these products when it is required. o, Lanking servic - -, , .1.. KINGS KITCHEN GENiLR •_ 't . • -•.•• P ••' - ,.• • , Harold E. Mabie, Jr. Owner FEM/ect https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - r 1 1- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis October 17, 1980 Dear Mac: I read your "foreign policy report" with great interest. The range of issues is so enormous -and so difficult -- one is tempted to react with despair about our ability as a people to get a rational handle on them. But the message that comes through in the end is that we really can -- once we look beyond the practical concerns of elections and re-elections and realize that people like yourself can provide the core of thoughtful consensus and leadership necessary. With best wishes, Sincerely, The Honorable Charles McC. Mathias, Jr. United States Senate Washington, D. C. 20510 PAV:ccm #388 CaiIA.111114235 112rDEPTA HD Fic C.I TIIIIA, WAVIr10 18 51111DTAIMEC October 8, 1980 Dear Paul: I am enclosing a statement which I released last week entitled "Toward a New American Foreign Policy." In it, I have tried to take a comprehensive look at what constitutes "national security" in this day and age. I have sought to avoid dwelling on our past successes and failures and instead have concentrated on what I believe should be our national security priorities for the future. I thought that you might find it of interest. With best wishes, /; • t, , Sincerely, I t r ' !k Charles McC. Mathias, Jr. United States Senator - The Honorable Paul A. Volcker Chairman, Board of Governors of the Federal Reserve System 20th and Constitution, N.W. Washington, D. C. 20551 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ,4* /16 • • Congressional Record S • United States of America Vol. 126 PROCEEDINGS AND DEBATES OF THE 96th CONGRESS SECOND SESSION WASHINGTON, TUESDAY, SEPTEMBER 30, 1980 No. 153—Part II Senate TOWARD A NEW AMERICAN FOREIGN POLICY Mr. MATHIAS. Mr. President, we have all been following closely the war taking place between Iraq and Iran. All of us recognize that although only two nations are directly involved, at present, in the fighting, the global implications of their conflict could be very grave indeed. The potential for serious energy shortages in the West, escalating regional violence, and superpower friction arising out of the current Iraq/Iran confrontation cannot be ignored. We need desperately to set a prudent course through these troubled waters. Our foreign policy must be one which is responsive to the full range of threats affecting our national security and yet guides us in pursuit of clearly defined priorities. I should like to explore this subject in detail with other Senators and with the American people. PART I--'HZ CHAILLXNGZ8 OP THZ 198013 Americans, with good reason, look back on much of the post-World War II era with some degree of nostalgia. The many International crises we faced during the period prior to our Vietnam engagement were very real. Some, such as the Cuban missile crisis, were potentially catastrophic. But, in retrospect, we never had it so good. We were, in fact and in the perceptions of our friends and foes, the strongest nation on earth. Our major adversary, the Soviet Union, could operate with impunity only within its relatively narrow sphere of influence. Its ability to project its power beyond the territory it overran during World War II, was restricted. Its global role was largely that of a spoiler, not of a shaper, of events. Economically, we had no rival. We were active participants in a global economy, the framework of which was largely shaped to our specifications. But we were not directly dependent on that world economy for our ultimate security. Foreign trade was in no sense critical to our survival as a free and functioning society. Finally, and critically, there was a high level of popular support in the United States for an activist American foreign policy along the lines of that pursued by the administrations in office in the 1950's and much of the 1960's. The "containment" of Soviet power was a goal acceptable to the American people. The strong American domestic economy made the pursuit of that goal all the easier. The Vietnam war helped to erode both the economic and popular underpinnings of American foreign policy. Americans came out of that experience with an altered view of the world and, most particularly, with an altered view of our role in it. The domestic base for an activist U.S. foreign policy seemed to have dissipated by the early 1970's. (The Nixon doctrine, with its stress on giving others the tools to pursue our interests, was the policy consequence of this shift in popular sentiment.) But what only became clear in the latter half of the 1970's was that the world, and our relative position in it, had shifted fundamentally. What is less clear is whether or not Americans appreciate the https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis felt everywhere. In 1978, the U.S. oil imextent of the changes and are prepared port bill was $42 billion. This year, it may U.S. to deal with their implications for well top $90 billion. In the nonoil prointerests. developing countries, the situaducing vital it is 1980's, the As we embark on particularly grim. The Economist tion is we world a of sort what understand to estimates that "Every time the price of are operating in and what sort of forces oil rises by $1 a barrel, the nonoil LDC's will impact on our interests in the years Developed Countries) have to worth (Lesser are ahead. The following points $2 billion more a year to pay nearly find emphasizing: It is estimated that imports." Soviet their the 1960's. for early the First. In the LDC's must come up with $65 billion Union embarked on a major effort to to pay for their imported oil this year build up its capabilities in the strategic convenand nuclear alone. tactical nuclear, been has effort This fields. In the past, adding to debt as well as military tional increasing exports have helped to fund sustained up to the present with annual LDC oil purchases. These funding avemilitary expenditures amounting to from nues are in question. 11 to 14 percent of Soviet GNP (as of percent 5 approximately The Third World is already heavily against our with debt. It is estimated that burdened GNP) . larger a the debt of nonOPEC developing counThe result of this effort is a Soviet tries was approximately $250 billion at military establishment very substantially larger and far more capable than it was the end of 1979, up from $73 billion in 1973. It is not clear how much more fi15 or 20 years ago. nancing is available. On the export side, It is, of course, difficult to compare U.S./Soviet military capabilities with any with the deepening economic troubles of Europe and the United States, it is quesprecision. The two countries have emphasized different aspects of their force tionable that these markets for LDC exstructures. (We do not match the Soviet ports will remain stable (much less Union in numbers of tanks, but they have grow). At present, the United States and Europe take over 60 percent of LDC no equivalent to our carrier task forces.) Nonetheless, across a wide range of inexports. dicators of military strength, the Soviet Nor is the West immune from this Union is now challenging the United cycle. More than 30 percent of the total States. annual exports of the United States, It goes without saying that other facEurope, and Japan go to the developing tors must be considered in making the countries. Whole industries in the West comparison. For example, a substantial could be adversely affected by the LDCs' portion (roughly a quarter) of the Soviet Inability to import. Union's military assets are directed As if this were not enough, the world against the People's Republic of China, goes on adding people at a fantastic rate. whereas the PRC is not, at present, conThe population of this globe is now over sidered by us to be a significant threat to 4.5 billion and is expected to reach 6 bilthe United States. lion within 20 years. "Unless current But even granting the more varied trends are reversed," according to a nature of Soviet security concerns, one State Department report, "the growth of Is still left with a fundamental concluthe world's population in the last quarter sion. One major reason the world will he of this century will equal the growth in different for the United States in the world population from the birth of 1980's than it was in preceding decades Christ to 1950: 90 percent of that growth is that the other superpower is now our will occur in developing countries." military equal. From Cairo to Calcutta, Mexico City to Second. There is an =fortunate tendBangkok, young people are making deency on the part of some Americans to mands impossible for any government to believe that expanding Soviet power is meet and impossible for any government the only major threat to U.S. security in to ignore without incurring grave risks the 1980's. This perception, unfortuto its own future. They are asking for nately, is far from accurate. Economic. food, shelter, and work. They are straindemographic, political, and other forces ing the earth's resources to the breaking at work in the world today are reshaping point. the very environment in which we will These many and varied pressures have to operate in the 1980's. These undermine the political stability of naforces could ultimately have far greater tions all over the globe. Governments are impact on our Nation's security than will are being replaced with regularity. Authe Soviet Union. thoritarian solutions to governance probWe are, for example, witnessing a trelems are becoming more common. Leadmendous transfer of wealth to the oil ers are driven to desperate measures to producing nations of the world. The imdivert public attention from the ecoplications of this transfer are still only nomic ills which plague them. The 1980's clear in outline, but the emerging picture promise to be a decade of great political Is not a reassuring one. instability. It is estimated that OPEC's net finanThird. Some Americans still believe cial assets will reach $380 billion by the that we can isolate ourselves from the end of 1981, up from $8 billion in 1973. In misery of the rest of the world. The thirst 1980 alone, thanks to the Precipitous major reason that the 1980's will be difprice rise in 1979. OPEC's current acferent than preceding decades is that it count surplus will top $100 billion, up is now very clear that such isolation is from about $7 billion in 1978. no longer an option for us. After World Indeed, the World Bank estimates that War II, we took on global responsibilities "the real price of oil is likely to be at voluntarily: today we have no choice. least 80 percent higher in 1980 than in The United States provides the ulti1978." mate counter weight to expanding Soviet The impact of higher energy prices is power. No other country, or group of • The challenge to American foreign policy countries, can realistically expect to Is to understand that we are broadly inwithstand Soviet military pressure withvolved and our responses must be broad. out the credible backing of the United We must not be lulled into believing that States. we can escape our problems or goaded This basic fact imposes great risks and into thinking'they can be resolved by responsibilities on us. The dangers of a military solutions alone. We face two regional conflict escalating and drawing vital imperatives, in Harvard Prof. Stanin the superpowers is all too real. The ley words,"the imperative to Hoffmann's balance of nuclear terror is so delicate evaluate correctly our own predicament that the risks of miscalculation must and the imperative to think in the long never be minimized. At the time of the term." Cuban missile crisis, one side backed PART II—THE DO UCESTIC BASE Or AMERICAN FORdown. The next time, the world may not ZION POLICY be so lucky. the The problem that we will face in These are the challenges Americans 1980's—as the example of Iran graphicalwill face in the 1980's. We must ask ourly illustrates--is that the internal reselves whether we are philosophically and sources and cohesion of many countries Institutionally ready and able to meet are being sapped by the forces discussed them. The answer is no. above. In Korea., Thailand, Pakistan, PHILOSOPHICAL CONSTRAINTS Turkey, Saudi Arabia, and other counAmericans' view of the world has been tries important to the United States, inconditioned by our country's geographic ternal processes at work are weakening Isolation and its historic material selfthe ability of these countries to control sufficiency. We have never had to get their own destinies. along with other peoples. We have never We are also experiencing divergences had to understand perspectives other in interests with our most valued allies than our own. And we find it difficult to in Europe and the Far East. These could do so. become fundamental and unbridgeable. The world, for us, is divided into good For example, the United States only imand evil. We are, by definition, on the ports from 40 to 50 percent of its oil side of the angels. We do battle with the and relies on its sizable domestic proforces of evil and are surprised when even duction for the balance. Europe and our friends do not see the global chalJapan have no such cushion.(Japan imlenges the same way we do. Because we ports over 90 percent of its oil consumpfail to understand what concerns or motion.) As one observer puts it, these tivates others, our global policies too countries live "closer to the edge of often appear irrelevant or dangerous to catastrophe." This basic fact has condiothers. tioned very different European/Japanese Because we are used to having our responses to Middle Eastern problems in own way within our own geographic general and the Palestinian issue in parsphere, we find it difficult to apply our ticular than those of the United States. power subtly and effectively in other In addition, our attitudes on East/West spheres. We favor quick, technological relations have been diverging more and solutions to problems. We are prone to more recently. believe that the global influence of a But more than strategic necessity and nation is only or largely a function of political reality bind us to the rest of the Its military strength, and that global world. Like it or not, the United States problems are amenable to military soluIs no longer economically independent, a tions. We are uncomfortable with nuance bald fact which by itself dictates our or compromise. active role on the world scene. INS'Iii u IC NAL CONSTRA1NTS The United States relies increasingly on the rest of the world for its raw maMany of our foreign policy problems terials. In 1950 we imported only about have institutional roots, both in the executive branch and in the Congress. 15 percent of our raw mineral needs. We One overriding problem is that Amernow import close to 35 percent. For exforeign policy originating from the ican ample, we import over 90 percent of the executive branch has, in recent years, maganese,cobalt, bauxite, and chromium we use. But imported energy is our most lacked continuity of purpose and direccritical dependency. In September 1973, tion. The extensive personnel changes we imported 3.4 million barrels of oil per with every new administration have undermined the purposeful conduct of day. I n August 1979, we imported 6.7 million barrels of oil per day, almost foreign affairs. President Carter, for double the 1973 figure. This amounts to example, put his own people into 16 of over 40 percent of our daily consumpthe top 22 positions in the State Departtion. Approximately 25 percent of our ment. We are reinventing the wheel oil imports come from the Persian Gulf. every 4 years or less. During the same period, our domestic Moreover, every department of govproduction, even with Alaska coming on ernment seems to be actively engaged line, stayed essentially flat. in foreign policy related activities. For There is every prospect that in the example, our relations with Mexico are conducted through State (diplomacy). 1980's U.S. dependence on imported raw materials will increase. In fact, the U.S. Energy (oil), Commerce (trade), Justice Bureau of Mines estimates that by the (illegal immigrants), and so on. Try as year 2000 only 20 percent of our primary it does, the bureaucracy cannot seem to materials will come solely from domestic weave these different strands into a serviceable fabric. The National Secusources. This dependence on imported raw marity Council should do so, but since McGeorge Bundy it—or at least the senior terials is only one aspect of an increasadviser—has too often operated as an ing U.S. involvement in a global econadvocate of its own point of view rather omy. In 1960 exports provide 5 percent of our GNP; by 1979 this figure had risen than a distiller of other bureaucratic viewpoints. to 10 percent. Today, every third acre The complexity and unwieldly nature of farmland in the United States and of the U.S. foreign policy process has every eighth manufacturing job probeen further complicated by the entry duces for export. onto the scene of a new participant-Those who say that we can ignore the In the early 1970's, Congress Congress. Third World should ponder the fact that itself in the foreign policy reasserted the bulk of our imports of raw materials a period of some passivity. after arena comes from developing countries. Today, the process has been influon effect Its Western to LDCs than we export more to changes in the nature recent enced by Europe and Japan combined. The twelve itself. Congress of the fastest growing markets for American The dispersal of power among Memexports today are in developing counbers of Congress reached a new peak in tries. Today, party leaders cannot 1970's. the this on the U.S. The impact of all members' votes. Chairmen their deliver domestic economy is profound. The U.S. their committees. The deliver cannot dollar is the currency of the world. Its Congress in the 1970's joining Members declining value relative to other currenlot than their disciplined less a are cies pushes up the price of U.S. imports, as an Congress predecessors. Moreover, fueling American inflation. The U.S. Institution has dispersed foreign policy Government Ls unable to exert adequate issues across a range of committees. It control over the dollar assets held by forhas no coordinating mechanism analeigners, thus restricting our ability to to the NSC in the executive ogous resolve our inflation difficulties. branch. We cannot retreat from the problems Despite these shortcomings, Congress which face us, but neither can we give injected itself into the foreign policy has confront us. In to the pressures which https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 411k cess with a vengence. Its primary impact in recent years has been to restrict executive branch initiatives, not to formulate policy. The congressional review process has often been constructive. It has also been pernicious at times. Members of Congress often find it difficult to fit individual foreign policy issues into a larger framework. Aid issues. military sales issues, and even major treaties are too often examined in narrow and parochial terms. There is too little real understanding of the need to sustain foreign policy initiatives with the effective use of foreign policy tools (military, assistance, trade). RECO M MENDATIONS A successful foreign policy is dependent on successful domestic policies. To a large extent our foreign policy problems have domestic roots. There are a number of actions we could take at home to make our efforts abroad more fruitful. For example: First. We put great stock in the image of military might which we project abroad, but nothing has so undermined our credibility in recent years as our inability to get our own economic house in order. Americans traditionally have paid little attention to the position of the U.S. dollar abroad. For foreigners however, this is a prime indicator of the strength of the American economy. The dollar's precipitous drop in value deeply troubles our friends as has our continuing failure to gain control over our excessive use of energy, our inflation rate, our declining productivity, and our low national rate of savings. These all suggest to foreigners that we cannot manage our affairs, that we are weak and unreliable. For many foreigners, these economic weaknesses are more important than whether or not we can deploy the 82d Airborne rapidly to the Persian Gulf. We must get our economic house in order if for no other reason than that it is a vital underpinning to an effective foreign policy. Second. The NSC and the job of the National Security Adviser should be returned to what it was most recently under Brent Scowcroft and before that under McGeorge Bundy. The NSC should bring the bureaucratic strands together. It should not be one more competing agency in the Government. Ideally, power in the foreign affairs field should be restored to the one department of the U.S. Government designed to manage it—the State Department. At the same time, there has to be greater expertise and more continuity of leadership in that organization. The periodic house cleaning that takes place, in the Department itself and in our ambassadorial ranks, does much to reduce the effectiveness of our diplomacy. Our professionals have a great deal to contribute; they should be better utilized. Third. U Congress is to be constructive in its foreign policy interventions in the future, not only attitudes but institutions will have to change. Perhaps the single most effective action that could be taken would be to establish some sort of coordinating mechanism to bring together the work of the several committees with jurisdiction into a unified foreign policy framework. More generally, members of Congress will have to develop greater sensitivity to the serious and far-reaching implications their actions have for both foreign and domestic policy. A cut in U.S. contributions to the World Bank, for example, can show up as an increase in American energy bills or in decreased exports of American companies. The Congress is inherently subject to the force of public opinion in both domestic and foreign policy. It is therefore important that foreign policy issues be framed so that public perceptions are not polarized along narrow and emotional lines. Otherwise the Congress will only intensify its own problems and its own pain while helping to mislead the country. To make a start at solving our problems, all Americans must learn to appreciate the complex interdependencies of the world we live in. U we do not help Mexico with its employment and population problems, there will be serious consequences for us further down the road. If a Khonaeint comes to power Saudi Arabia, we vrill feel the effects ot ttiat change at the gas pumps. If the Soviet TJnion does not find our military c,apabilities credible, we will have to confront increased Soviet global probing. The purpose of a strong milita.ry establishment is not to invite war but to deter Those who seek only military answers to our foreign policy problems, however, fail to understand that many of these problems IS not lend themselves to m tary solutions. We must. M short, begin to pull together, if we are not to pull apart. To do that, we need a strategic policy abroad which can promote American interests and command the support of the American people. PART I. STRATEGIC TORSION POLICY !OR TYKE 19030'S America sits astride a crossroads without a map_ A troubling agenda of international problems faces us, but we lack tI. conceptual framework to address We could, of course, conduct our international relations on a piecemeal, reactive basis, jumping from issue to issue. But every administration since World War II has recognized that this approach is not in our best interests. Without some sense of direction and purpose, our foreign policy is ultimately doomed to flounder. We live is: in a world of radical change. Whether we become victims or beneficiaries of this change depends on the measures we take in cooperation with our friends to meet the challenges of a complex and changing world. U we are to I.ster the future, we must be strong— militarily, economically, and politically. But above all, we must be wise. Our priority must be to manage the changes we face skillfully enough to prevent the tide of world affairs from going against us. Specifically, our interests lie in insuring that: The Soviet Union does not so shift the S.lance of power against the West that it can dictate to us from a position of military supremacy or geographic control of vital resources. A regional conflict does not so escalate that the superpowers are drawn into a direct confrontation neither wants nor can survive. The proliferation of conventional arms and nuclear weaponry does not get out of hand th the point that conflicts of everincreasing intensity become a permanent feature of the world scene. The alliance system on which Western security rests does not succumb to narrOW economic protectionism and diverging political imperatives. The socio/political ideals of the Western democracies continue to find free expression around the globe. The fragile balance between man and his environment not be overturned by a world population that outstrips the resources that sustain it. The United States and her allies retain access to vital raw materials. To come to grips with these imperatives, we are left vrith a fundamental and continuing task—to persuade others to join us in building a raore stable world. The tangible IS of persuasion available to us are diplomatic, economic, and military. But they are also perceptual— the confidence others have in our strength, resolve, reliability and the soundness of our approach to world affairs. What is called for now is not a Pax i.e f cooperative Americana but a relationships which binds responsible members of the world corruaiunity in a common approach to the challenges facing all of us. Our problems are all shared problems, the solutions must be shared as well. For such a system to work, Americans must begin by setting a course designed to bring others aboard. What then should our direction be? Where do our priorities lie? PAST IV--OLOBAL PRIORIT/ILS ALLIES At no time since the 1940's has the need to coordinate our responses to global problems with our allies been so great. All the evidence suggests that the 1980's will expose the United States to an unprecedented range of threats to its https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis security. Soviet power will be relatively greater than. ever before. Global economic interdependence will be dranaatically accentuated. Indeed, if left to fester, the problems facing the Third political legitiWorld—determining macy, curbing population growth, or finding the economic resources to maintain life itself--could doom us all. V7e simply can no longer avoid the imperative of seeking coordinated Western responses to the common global challenges facing us. The United States cannot, and indeed should not,"go it alone." Our most fundamental priority is the preservation of Western unity in word and deed. Every U.S. administration since Truman's has supported allied coordination anI cooperation but, too often, the practical application of this support has been lacking. When Henry Kissinger went to China and when we ultimately normalized our relations with the People's Republic of China, Japan was among the last to know. Fortunately, Japan favored the policy—but its execution left much to be desired. Only when our allies participate itt the shaping of policy can we be co dent they will participate in its execution. Structuring a foreign policy grounded on cooperation is not easy. Consensus cS n be difficult to obtain. Many bases have to be touched. Moreover, our immediate interests may not be compatible with those of our allies. All parties have to keep firmly in mind the greater risks of a complete breakdown in alliance cooperation and coordination. The rewards of a cooperative allied approach to problems can be great. The military, political, and economic strength of the West simply cannot be matched by the Soviet Union and its unreliable client states. This strength, when applied in a cIS rdinated way, can have enormous impact. Another advantage to this approach is that there are problems for which there may be no American solution, but there could well be a French or Bsh one. The recent settlement in Rhodesia is a case in point. In sum, our fundamental priority is to II: .1 the strength and cohesion of the Western alliance. It is the sine qua non in our pursuit of every other interest of concern to US. ECONOMICS To a remarkable degree, our foreign policy must be developed with global economic reaes in rnind. U Western democracies are going to continue to function as free societies. effective control over global inflation must be achieved and assured access to raw materials guaranteed. U political chaos is not to engulf the Third World, economic progress must be continuous and significant. In an interdependent world economy, all countries have a stake in the smooth flow of goods and services between nations. All nations—to varying degrees--are vulnerable to any interruption of this flow. Economic imperatives increasingly dictate our geographic interests and is of our allies. Oil is a crucial factor in our approach to Middle East issues. It is a growing factor in our relations vrith Mexico. Inflation has become a global phenomenon and requires a global response. The burgeoning debt of the Third V7orld is a Western dilemma as well. The continued role of the dollar as the premier world currency remains a common problem in search of a common solution. Perhaps because we have such d culty in dealing with our domestic economy, we shy away from these vastly more complex international economic issues. But, this is a lthcury we cannot afford. The health of our domestic economy is tied to that of the world economy. A major priority of the United States must I. to pursue a strengthened global economy. SOVIET UNION have delayed examining the U.S./ Soviet relationship not because it is not critical, but to underline two points. First, for relations with the U.S.S.R. to be constructive, from our point of view, we must first reestablish good relations I lk ween the United States and its allies. Secon,. although the Soviet Union and the United States can destroy each other militarily, our vulnerability to economic catastrophe is a clear and present danger and would persist even were the Soviet threat to disappear miraculously overnight. Nonetheless. our competition with the other superpower will continue to be of vital U.S. national concern. This being the case, it is all the more remarkable that we lack any sort of national consensus on answers to basic questions concerning the Soviet Union and our relations with it. Consider the rouowing list: What are the fundamental interests of the Soviet Union and what are merely peripheral? `77hat is the nature of the Soviet threat to us? Is it prima,rily military or primarily political or potentially economic? Are there incentives or disincentives thS t influence soviet behavior? What are they? Is it in our interest to deny to the Soviet Union grain or oil field technology in order to undennine the Soviet economy? Or, by doing so, do we merely support those in Moscow calling for more vigorous confrontation with the West? In our dealings with countries on the Soviet border,should we be promoting an anti-Soviet alliance or should our approach be more balanced (i.e. What is na card"?) the role of the Finally, in our competition with the Soviet Union, should we be primarily cIS cerned with the "lessons" of 1939 when compromise was seen to whet the appetite of an implacable aggressor? Or should we be recalling the events of 1914 when the superpowers of the day were sucked into a catastrophic V7aX by the requirements of mobilization schedules and by the needs of lesser states embroiled in secondary concerns? Without having resolved fundamental I uestions such as these, we blithely continue to make tactical decisions of potentially enormous impact on the direction of Soviet strategic thinking. Playing the China Card and approving the introduction of nuclear armed cruise missiles onto German soil are two examples which come to mind. This is not to argue the merits of these decisions, but only to point out that decisions of such import as these should only be taken wn a much larger strategic cbntext. Tactical decisions on issues affecting the U.S.S.R. should only flow from a strategic view of Soviet intentions. What, then, is the threat that the Soviet poses for U.S. interests? It is obviously military. Soviet strategic nuclear, theater nuclear and conventional tary capabilities are sizable and expanding rapidly. Soviet defense expenditures are estimated to be running as much as 30 percent ahead of ours. Moreover, the Soviet Union has been demonstrating an increasing propensity to project its military presence internationally. Military equipment in vast quantities has been transferred to the Third World. Soviet, Cuban, and East German advisors have been active S round the globe. Cuban combat troops have been a significant force in such countries as Ethiopia. The Soviet invasion of Afghanistan represents only the latest escalation in Soviet activity. The Soviet threat to U.S. interests is also political. Soviet leaders pursue IIlicies•: .1 to separate us from our allies. Soviet agents seek to undermine regiI.-s friendly to the West. It is quite possibly economic. The Soviet Union may soon be a bidder in world oil markets and a competitor for other natural resources. Here again, Stanley Hoffmann articulates our dilemma. "Geopolitically," says Hoffmann. "as the main status quo II''er in a world a change, the United States is on a kind of universal defensive, wh.Ue its rival can pick and choose the points for attack from among the manY ferments of trouble." Wetoday, waiting for blowups in Yugoslavia, Pakistan, and elsewhere. In structuring a response to the Soviet challenge, we must, howrver, guard against being one dimensional. Our policies must be for the long term. Clearly, the U.S./Soviet military bal- • • ance must be maintained. We cannoill , liferation. Finally, we must deal with the lkst: permit either the fact or the perception continuing deterioration of the global First: Begin to negotiate with her al9f U.S. military weakness vis-a-vis our lies. The era of simple notification after environment major competitor to arise. But neither decisions is over. Our European friends, It is vital to stress that these global should our force buildup be mindless. Issues require our consideration quite if they are to be expected to lend their Instead of debating percentage increases apart from our pursuit of our other power to policies, must have a hand in in the defense budget, we should be interests. the formulations of those policies in talking about military missions and the No sensible animal fouls its own nest. genuine consultation. force structures necessary to carry them Yet man is progressively destroying his Second: This means that the European out. What should a Rapid Deployment environment Unless we actively move to component of our foreign policies must Force be able to do? The answer to that repair the damage, we will have to share increase. This is difficult for us to accept question should determine how we begin in the consequences. and understand, but it is this very deto structure the force. Dramatic population growth and hopeparture that could determine the success If only because perceptions matter, we less poverty in the Third World will inor failure of these policies. should soft-pedal what has become our crease the incidence of waves of refugees Europe must: excessive public denigration of our own cast upon our shores and pressures for First. Understand that with power strengths, military and otherwise. The more immigration. comes responsibility. Germany. France, world is far more unfriendly to Soviet Six nations have exploded nuclear must reorient their thinking Britain and interests than many would have us. bedevices. But a number of others are bechallenges which can unglobal the to Soviet Union lieve. The faces a Western lieved to be capable of doing so. The day regional security. The battheir dermine alliance with formidable military capamay not be far off when Libyans, Iraqis, tle for Bonn may be lost in Kabul or bilities. It is ringed by unfriendly neighand Pakistanis have nuclear bombs. Riyadh. bors. It cannot rely on its closest allies. That should be of concern to us. Second. The European component in It has little to offer beyond military Finally, and specifically, we should not global "burden sharing" must bethe hardware to Third World countries conlet our competition with the Soviet Union more significant. Americans must come cerned with economic progress and poso dominate our thinking that we are not be left with the feeling that they litical stability. unable to respond to Third World needs are alone on the front line while EuroBeyond,, maintaining our military except in terms of that competition. peans reap the benefits of detente. strength, we must be clear about our obOne of our greatest challenges—and THE MIDDLE EAST jectives. The Soviet Union must underworst failings—has been our inability stand clearly what we consider our vital The United States has longstanding to frame a constructive framework for interests to be and what penalties attach ties to certain nations in this region. responding to Third World challenges. to threatening them. We are, for example, committed for a Our security is at stake in the future Much of our response to the Soviet variety of good reasons to the security stability of Saudi Arabia and Nigeria. challenge must be political as well as and well-being of the State of Israel. Yet we understand little about the forces military in nature. The real threat to the A primary interest in the Middle East at work in these and other Third World Western alliance is not a Warsaw Pact of the United States and her allies is concountries. attack (though we must be prepared for access to adequate supplies of entinued PART V-REGIONAL POLICIES this) but the corrosive effects of diergy at "acceptable" prices. We get oneOur conceptual priorities—centrality verging interests among the allies being quarter, Western Europe two-thirds, and of alliances, economic imperatives, et exploited by Moscow. The primary Japan three-quarters of its imported oil cetera—have regional implications which threat in the Third World is not Cuban from the Persian Gulf. are important to consider. A sound U.S. troops and Soviet advisors but political Access to this oil is threatened by poforeign policy must be grounded in active Instability arising from economic and litical instability in the region, Soviet acand sensible policies in Western Europe, social roots. The Shah, even with his vast tivity, and by the continuation of the the Middle East, Japan. and the Westmilitary arsenal, could not withstand the Arab-Israeli conflict. ern Hemisphere. These regions must revolutionary forces at work In Iranian Ever since World War II, the Middle receive the focus of U.S. policy initiatives. society. East has been a region of political inWESTERN EUROPE In our anxiety to respond to the chalstability. The continuing search for nalenges posed by the Soviet Union, we tional identity and political legitimacy in Our relations with the major nations must not overlook what we have in comthat part of the world has not been an of Western Europe are fundamental to mon. Each superpower fears and expects easy one. The experience of Iran provides the United States. These relations are, the worst from the other. We each reonly the latest example of just how diffihowever, currently under strain for the tain the capability of annihilating the cult this process can be. It is quite posfollowing reasons: other. With the steady increase in and sible that abrupt shifts in the ruling The credibility of American strength, diversification of our respective nuclear elites, such as took place in Tehran, will reliability, and commitment is widely arsenals, the underpinnings of deteroccur in other countries in the region. questioned in Europe. The European rerence may be eroding. Nuclear war may Soviet activity in the Middle East must sponsiveness to global challenges is become a greater possibility in the years also be viewed as threatening to us. In Washington. doubted in ahead. recent years, as has been noted earlier, Europe and the United States appear We tend to forget that accommodation there has been a particularly deterto have divergent interests on Middle with the Soviet Union, if managed prumined effort by Moscow to expand its East and East-West issues in particular. dently, can be in our mutual interests. influence in that part of the world. This Economic problems on both sides of The air we breathe is less deadly because effort has not always met with success, the Atlantic inevitably promote talk of both nations are abiding by the 1963 but it continues. The Soviet use of surregional or national rather than Western Test Ban Treaty, We share a need to rogates such as the Cubans and East responses to these problems. control nuclear arms and reduce the Germans is a particularly worrisome Nonetheless, there remains widespread possibility of conflict. phenomenon. understanding of the overriding comIn short, we need a decathlon policy The Arab-Israeli conflict represents a monality of certain Western interests. for dealing with the Soviet Union. No dangerous situation for the United Only the Soviets can gain from a split single strength or skill will suffice. We States. There is always the possibility in the Western alliance, a split they are must have the capacity to take the initithat this conflict could expand into a actively attempting to promote. Moreative in the economic sphere, in political direct superpower confrontation. Moreover, the augmentation of Soviet milicooperation, in military power, in techover, the continued absence of an accepttary power has direct implications for nological transfer, in cultural exchange, able solution to the Palestinian issue afthe European balance. This is particuet cetera. fects our other relations in the Middle larly the case given the weakening of the We must evolve a policy toward the East. Quite obviously, our problems in Southern flank of NATO in recent years. Soviet Union which employs both the the region would not disappear if this Turbulence in the Third World poses a stick and the carrot. We must, on the and other issues were resolved. However. general threat to the West and a particone hand, be clear about our vital interour ability to concentrate on our pursuit ular threat to European nations dependests and our ability and willingness to of our other interests in the region would ent on raw materials for their economic defend them. But, on the other hand, we be enhanced by an enduring resolution— survival. Yet institutionally, in the milimust also understand that the Soviet that is, acceptable to Israel and the tary sphere in particular, we are not Union has vital interests of its own. —The Arabs—of these issues. prepared to deal with conflicts outside worst possible situation," writes Seweryn of Europe. NATO was set up to respond We have not been very adept at conBialer of Columbia University, "is when to European not Middle Eastern crises. structing policies responsive to these the U.S.S.R. feels that it has nothing to The United States, and her key Eurochallenges. We have yet to determine the fear from the U.S. and nothing to gain." pean allies, must begin by stepping back proper balance between maintaining the In the final'analysis, we should seek from the tactical discussions—Afghanstatus quo and recognition that inevitstability and predictability in our relaistan, trade, Iran, and so forth—which able change in the region will leave us tions with our major competitor. occupy so much of our time, and try to behind unless we are nimble. Moreover, GLOBAL ISSUES reach a consensus on the strategic chalour tendency has been to "go it alone" lenges which face our alliance. Only then in the Middle East in the last decade. We Our relations with our allies, our intercan cooperative programs be devised to national economic concerns, and our abandoned the Five Power talks for onemeet these challenges. man shuttle diplomacy. We are now decompetition with the Soviet Union are, The strategic framework for our Eastveloping a Rapid Deployment Force for of necessity, priority concerns for U.S. West and North-South relations must be the region that could send us hurtling policymakers. But these issues cannot be constructed so that crises, such as are into the Middle East alone and unaided. permitted to dominate our thinking to occurring now in Afghanistan and Iran, We must begin by recognizing that the extent that we ignore the host of can be dealt within the context of larger "global" Issues that ultimately could there are severe limitations on our ability realities. have a far greater impact on our Nation's to maneuver in that part of the world. security and well-being. There is a tendency in some quarters in Only in this way can we mitigate the It is increasingly clear that we must the United States to want to believe that inevitable tactical disagreements which devote more attention to the Third World our only problem in the Middle East is are today splitting the alliance. and Third World issues—political legitithat we are no longer respected. Our But if these programs are going to obmacy, population, hunger, debt, trade, "power" is no longer feared and our tain the necessary consensus support. "will" is in question. and security. We have to concern ourthere will have to be accommodation by There is an element of truth in these selves with the question of nuclear proall parties. Specifically, the United States https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis assertions, but to the extent that the", adherents believe we can restore American influence through the use of military iforce alone, it is a dangerous misconception. We have to recognize that the nations of the Middle East suspect us of having ulterior designs in the region. For us to use our own military forces to resolve what is seen as an internal Middle East issue would be to confirm their worst fears. It would not lead to greater respect. It would lead to a far greater regional coalescence against an external American threat. We must, in short, walk a fine line in which we make clear our ability to defend our interests without exercising that ability indiscriminately in a misguided effort to demonstrate our will. This suggests, of course, that we must begin to involve our aMes--regional and external—far more than we have in the past in cooperative approaches to regional challenges. We must have priorities. Recent administrations have been right to focus on resolution of the Arab-Israeli conflict. Our ability to work constructively with both Israel and Egypt will be enhanced when these countries are no longer isolated in the region. Quite clearly, we must provide more effective responses to Soviet challenges. Augmenting our naval capabilities in the Indian Ocean is certainly necessary. We must not, however, permit Soviet activity in the Middle East to blind us to the underlying political/economic problems in the region. These countries will develop their own antibodies to Soviet expansion if we assist, not threaten. them. FAR EAST The United States has vital strategic interests in the Far East. They affect both our security and our economic wellbeing. These interests include: insuring the safety of U.S. allies in the region: maintaining regional stability particularly with respect to possible conflict situations in Korea, Taiwan or Southeast Asia: and promoting stable economic relationships between the United States and the countries of the region. The cornerstone of our Asian relations is, and must continue to be, Japan, our strongest and most reliable ally in the area. Japan has the second or third largest economy in the world. It is strategically located and is tied to the United States by mutually binding treaty commitments. U.S. relations with the Japanese have not always been easy. Our refusal for many years to normalize relations with the PRC and our involvement in Vietnam strained our ties with Tokyo. Economic differences remain an ever present source of potential friction. Nonetheless, there is a general understanding on both sides of the Pacific that what binds us is far greater than what separates us. It is important, therefore, that our commitment to the relationship be strengthened. The Japanese are understandably concerned by our talk of troop withdrawals from Korea and a "swing" defense strategy that would send U.S. Pacific-based military assets to Europe in the event of a crisis there. Sending our 7th Fleet carrier task farce to the Indian Ocean did nothing to dampen these concerns. Our relations with Korea are of a different sort. We have a historical commitment to that country's security, which is vital to maintain if for no other reason than that Korean security has great significance for Japanese security. Our most difficult regional policy dilemmas are with the Peoples' Republic of China. Few disagree that cooperative relations between the PRC and the United StatPs are in the mutual interest of both countries. It is much less clear how close these relations should be. We have tended to display great enthusiasm for the PRC connection without, perhaps, sufficiently considering the pitfalls of overplaying the China card. Chinese leaders have attempted to draw the United States into a more confrontational stance vis-a-vis the Soviet Union. These efforts have, of course, provoked considerable concern in Moscow. A little bit of Soviet uncertainty regarding the extent and purpose of United https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Sts.tes-PRC ties is not unhealthy. Henry Kissinger understood this well. But too much uncertainty could be catastrophic. The point is a relatively simple one. The Soviet Union has the military capability—and may also have the necessary paranoia about Chinese intentions—to wipe out the People's Republic as a functioning society. It is in our interest to Improve our relations with Beijing but not at the expense of creating major tensions in Moscow. Our relations with the Soviet Union and our interest in avoiding a major Sino/Soviet military confrontation must temper our hot pursuit of improved ties with China. We should certainly proceed with the improvement in our economic and cultural interaction but stay away from military ties with Beijing. Whatever improvement in United States-People's Republic of China relations occurs will have to take place despite the internal political instabilities in China and the nonresolution of the Taiwan issue. We cannot hope to have much effect on the first and must remain resolute in our ingistence that the second be resolved by peaceful means. In the rest of the region, we must continue in the closest relationship with Australia and New Zealand. We should seek to understand and respond sympathetically to the economic aspirations of the people of Asia. But, we cannot expect to exert great influence on their security arrangements. The response, for example, to Vietnamese expansion must come largely from local forces not American. WILSTERN HZ WISP 11:13112 We have historically neglected our relations with our neighbors. Key bilateral relations have not been properly nurtured and regional priorities have traditionally been overshadowed by other foreign policy concerns. Three countries, in particular, are of critical importance to the United States in this hemisphere Canada, Brazil, and Mexico. The United States has traditionally devoted insufficient attention to its relations with its northern neighbor. We have assumed too much. It is not too late to rectify this mistake, but considerable effort will be required on our part. Canada's interests do not necessarily converge with ours and managing our differences in the decade ahead will be of vital importance to both of us. Brazil has traditionally had close relations with the United States. In the economic field, 19 percent of Brazil's exports go to the United States, we supply 16 percent of Brazil's imports, and our banks supply close to a third Jf Brazil's foreign debt. In each of these categories. we are Brazil's largest partner. However, Brazil is determined to chart a course independent of the United States. It is determined to play a role on the world scene commensurate with its size—fifth largest country in the world—population sixth most populous with 125 million inhabitants—and economic clout—eighth largest Western economy with a 1979 GNP of $200 billion. For the United States to deal with Brazil constructively, we must be willing to address ourselves to the issues— largely economic—which concern her. Bra7i11ans recognize that their fate is, in part, tied to ours. An economic recession in our country inevitably has negative repercussions in Brazil. What Brazilians want and need is U.S. movement on commodity, trade, and technology transfer issues. If Brazil's economy is to maintain its impressive growth rate, her commodities must be traded in a more predictable pricing environment. She must have access to our markets and to our technology. By the mid-1980's, Mexico could be our largest single trading partner. At present, Mexico sends over 70 percent of its oil exports to the United States. It could becume a growing source of energy for us In the future. There are, however, severe strains in our bilateral relations. These are, in part, inevitable. Mexico is seeking a separate role in the region and the world. Inevitably, this involves distancing itself from the United States on certain issues. We, on the other hand, have not been sufficiently sensitive to Mexico's special con- e rns. We have not accorded that country the respect it deserves. We can no longer avoid the problems and the opportunities that exist with regard to United States-Mexican relations. Mexico has a population of 65 million which could double by the year 2000. Today 30 million Mexicans are under the age of 14. Mexico is our largest single source of undocumented aliens Unless this problem is dealt with, it will plague our relations for years to come. Part of the solution may be in the fact that 8 of Mexico's 32 states account for 80 percent of all Mexican migration to the United States. If we could help solve the economic problems in those states, the Issue of illegal immigration could become more manageable. But the United States needs not only good bilateral relations in the Western Hemisphere, it needs good regional policies as well. This is particularly the case with respect to the Caribbean area. We have unwisely neglected the Caribbean region. It should be a vital regional priority of the United States to remedy this neglect quickly. The Caribbean, and the countries in and around it, form the strategic underbelly of the United States. Through the Caribbean flows more than 50 percent of our annual oil imports. It commands the entrance to the Panama Canal. It—in particular Jamaica—is the source of much of our bauxite. Last, but not least, the Soviet Union has established a presence there which is potentially threatening to us. These are all sound security reasons for paying more attention to the countries of the Caribbean, but there are domestic American reasons as well. The United States is now the fifth largest Spanish-speaking country in the world. The 17 to 22 million Hispanic Americans may shortly be our largest minority. Moreover, the Caribbean is now our second largest source of undocumented aliens—after Mexico. The barriers to effective U.S. policies in the Caribbean are enormous. Political instability is endemic to the region. It arises out of the failure of nations in the region to reach internal agreements on issues of political legitimacy. Who should hold power and how should power be transferred? These political problems are exacerbated by severe economic and demographic strains. The combination of economic mismanagement, high oil prices, and low commodity prices has created a regional economic depression. High unemployment is rampant. High emigration saps the regional talent pool. All these problems are made worse by a dangerous demographic situation. The median age in the Caribbean is 16, as compared to 29 in the United States. The young people in the Caribbean, collectively, constitute a time bomb set to explode. We will have to live with the inevitability of change—sometimes violent—in the region. We must awaken to these challenges. Certainly we must not neglect the possible military implications of joint SovietCuban activity in the region. But real problems also lie elsewhere. We cannot deal with them by blaming Cuba for all the unrest in the area. The Soviet Union would like nothing better than to have the Caribbean polarized between those who are "with us" and those who are "against us." I can, therefore, think of no region of the world for which it is more important to have sound aid and trade policies. We will want to achieve the proper balance between bilateral and multilateral assistance. But there must be no question that the United States is not ready to assist in the economic rehabilitation of the region. We must also be more receptive to exports from the Caribbean. Exports mean jobs for these countries and until unemployment is reduced political Instability will be a fact of life. In the final analysis, however, we can only assist the countries of the region to assist themselves. cctohor 176 1980 -ihet Uonorable william Proxmire CeJ.Talittee on ranking, Housing 4nd rIrlar. Affairs L'nitecl ti!tates Senate 20510 ' ton, r.C. Dims CI-airman Proxmire. on the Thank ycu for or Cctol-ier 1 letter oor7,menting c articularly concernee proeoscd revision of Reculation Z. You are titernate shorpirg about that portion of the Jraft allovi:lg for - early dirclosures disclosures. While you endorse the conceit cq :.elieve tN4t tl'te to encourage the informed use of credit, you .e creditors mi7,?-t k roposed draft could create a loophole ty 14;:l avoid making comilete disclosuras. shorTing The Board's proposed provision for alternate s and creditors. diaclosures was Intended to benefit both consuner early di,sclosure ide It wiz d(esi(Ined to encouraffe cryelitors to prov bettor opportunity of credit costs, there:b.:id ellowine; consumers a it. T"te proposal to sisop and en9age in the informed us* of cred lation. as you know represented a dei,arture frofil the current requ cific coent a% to t$het1;er and the Board thercfore scaicited cretlit e•orTtnq function the “vposed diccloures would promote tEc4 of the Truth in Len4:in9 Act. ely The oowronts received on the iroTosal were larg rs expressed con• nejative; botE industry and consumer commente alternate disclesurits. corn about ti.e rotential problems posed by to determine }ow As a result, staff is restudying the prol.yosal nce the crOit best to carry out the Board's cmamitment to enha long-standing shopping functios; of the Act. IL view of your ttke Board appreinterest and involveaent in Truth in Lending, keyt in rind in ciates having your coaments and they will Le credit shopcinej any revision that we aaght oak* to improve the function of the disclosures. Sincerely, S/Pau1A.VoIçUL CtLD.M.00apjt (11V-37) r. Hurst Lcc . (2)w--" Paula rice (for diztribution) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • WILLIAM PROXMIRE. WIS.. CHAIRMAN HARRISON A. WILLIAMS. JR., N.J. ALAN CRANSTON. CALIF. ADLAI E. STEVENSON, ILL. ROBERT MORGAN, N.C. DONALD W: JR., MICH. PAUL S. SARBANES. MD. DWALD W STEWART, ALA. G. /RGE .1. MITCHELL, MAINE JAKE GARN, UTAH JOHN TOWER, TEX. JOHN HEINZ, PA. Action assigned Janet HartAh 11, WILLIAM L. ARMSTRONG. COLO. NANCY LANDON KASSF.BAUM, KANS. RICHARD G. LUGAR, IND. KENNETH A. MC LEAN. STArr DIRECT OR M. DANNY WALL, MINORITY STAFF DIRECT OR MARY FRANCES DE LA PAVA, CHIEF CLERK 'ZICrtiteb ,23.fafes, Zerrate COMMITTEE ON BANKING. HOUS ING, AND URBAN AFFAIRS WASHINGTON. D.C. 20510 October 1, 1980 The Honorable Paul A. Volcker Chairman Board of Governors of the Federal Reserve System Constitution Avenue between 20th and 21st Streets Washington, D.C. 20551 Dear Chairman Volcker: The Board will soon be consideri ng the proposed revision of Regulation Z. I wish to indicate serious reservations con cerning that section of the revision relating to advanced dis closures. While I concur with the Board that the concept of advance disclosure has the potential to greatly encourage the informed use of credit, promul gation of this proposal in its present form would most certai nly undermine not only the potential utility of this concept but the basic premises of TIL its elf. On October 29, 1979 I stated my support for advance disclosure on the Senate floor. I specifically noted that the benefit from such advance disclo sures would derive from the fact that "the borrower could review credit cost information when applying for credit, at a time when credit shopping is possible, rather than obtaining the disclosure at the loan closing". Unfortunately, your proposal does not in any way differentiate between transacti onal circumstances where the borrower is making tentative inq uiries concerning the cost of borrowed funds and those situation s where the borrower is sitting down with the creditor to consummate the agreement to extend credit. The failure to make this distinction will undoubtedly permit any number of unscru pulous creditors to avoid making complete disclosure merely by supplying the borrower with "advance" disclosures at the consum mation of the transaction as permitted (if not encouraged) by this loophole. Another obvious weakness of this proposal would permit the disclosure of an amount financ ed which may be as much as 10% at variance with the actual amount financed. This permissible variance, without any dollar limitation, would be particularly troublesome in the case of larger consumer credit transactions, https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis it https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The Honorable Paul A. Volcker -2- October 1, 1980 such as home improvement and mobile home loan s. For example, your proposal would permit an aluminum siding firm to solicit a family, in their home, to purchase siding and to consummate a 15 year credit transaction for $16,200 with this family, all on the same day, while providing only "adv ance" disclosures with a grossly understated amounted financed of only $15,000. Obviously, any advance disclosure of the tota l finance charge would be similarly understated. The potentia l for mischief is unmistakable. I would therefore urge the Board to reject this advance disclosure proposal until such time as these deficiencies have been obviated. I trust that we are in agre ement that advance disclosure deserves a much stronger foundati on than would be provided by this particular proposal. Sincerely ) William Proxmire Chairman WP:lgj BOARD OF GOVERNORS Oc THE ••••• • RAL FEDERAL RESERVE SYSTEM t-1 • (-) , 144'• REc. -0%-• • WASHINGTON, D. C. 20551 PAUL A. VCJLCKER CHAIRMAN October 20, 1980 The Honorable Don Ritter House of Representatives Washington, D. C. 20515 Dear Mr. Ritter: I want to thank you for your rec ent letter describing H. R. 7655, which would reduce per sonal and corporate tax burdens and limit the growth of federal spending. Last month I had the occasion to discuss the tax cut issue with the House Budget Com mittee, -so my comments regarding H. R. 7655 probably will come as no surprise to you. I continue to be concerned that the fiscal pol icy proposals before the Congress--including H. R. 7655 and the Senate Finance Committee's bill--would prove detrimental to our nation's long-run economic health. While there is an unders tandable desire to foster a vigorous recovery from the curren t economic downturn--and to ease personal and corporate tax bur dens--we must not lose sight of the implications that an expans ive budgetary policy would have on inflationary expectations. In our current environment, any deviation from a commitment to a sustained fiscal discipline is likely to have a destabilizing eff ect on the public's view of the prospects for a return to price stability. As a result, any benefits accruing from a tax reduct ion may be dissipated in further financial and price pressures. I agree with you that a well-str uctured tax reduction can make an important contribution to solving our nation's economic difficulties. The tax system can be adjusted to add incentives that encourage capital formation, and thereby enhance productivity growth. As your let ter suggests, a tax reduction also can help relieve the pressu res that have been placed on many household budgets by a com bination of rising living costs and increasing marginal tax rates. A decision on the size and timing of a tax reduction, however, must be reconciled with the nation's economic outlook and the government's budgetary stance. All evidence points to https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 111 The HDnorable Don Ri tter Page Two a substantial growth in federal spending in the year ahead. groWth coupled with st This rong inflationary trends already in pl argues ayainst a tax ace cut of the magnitud e embodied in H. R. Until restraint is de 7655. monstrated on the spending side of th anyHirIcrease in the e budget, deficit would be vi ewed as inflationary wou).d pose a throat and to the recovery of such interest rate sectors as housing sensitive and autos. Gi\ien these factors, I continue to favor consideration of a ta delaying any x cub until early ne xt year. At that time some of the current , economic uncertaint ie s will be resolved an a clearer picture wi d ll emerge about the spending priorities the Congress and the of Administration, Th e next three to six months will provide an opportunity to re fine our thinking ab the structure of any out future tax reductio n. We want to be ce that it provides the mo rtain st efficient moans of achieving the ob of long-term economic jectives growth, price stab ility, and budget balance. Sincerely, SifautitvoIpifcr JSF:FMS:JSZ:vcd (#V-377) bcc: https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Messrs. Kichline, Struble, Fralic k, Zeisel Mrs. Mallardi (2)./ Action assigned Jim Kichline DON RITTER 15TH DfcTpirr. PENNSYLVANIA • SUBCOMMITTE(S: 124 CANNON OFFICE BUILDING WASHINGTON. 0 C 20515 (202) 225-6411 k,AgL14,10' COMMITTEES BANKING. FINANCE AND URBAN AFFAIRS • "." Congre55 of die HOUSING AND COMMUNITY DEVELOPMCNT 1)0MLST,C MONETARY POLICY CONSUMER AFFAIRS • SCIENCE AND TECHNOLOGY DISTRICT OFFICES: 1iiitebiptate5 ji)oufSe of ikeprefentatibes Zinaitington, 33.e. 20315 zi ' /134r Sul-re 1005 1 BETHLEHEM PLAZA HLEHEM. PENNSYLVANIA 19018 (215) 866-0916 ROOM 212 ALLI NTOWN POST OrrICE BUILDING ALLENIOINN. PENNSYLVANIA 18101 (215) 439-8861 September 26, 1980 R00M 705 AL PHA BUILDING EASTON. PENNSYLVANIA 18042 (215) 258-8383 SUBCOMMITTEES. ENERGY DEVELOPMENT AND APPLICATIONS SCIENCE. RESF ARCH AND TECHNOLOGY NATURAL RESOURCES AND ENVIRONMENT Mr. Paul A. Volcker Chairman-Board of Governors of The Federal Reserve System 20th and C Streets, N.W. Washington, D.C. 20551 Dear Mr. Volcker: I thought you would be interested to learn of a major new legislative proposal to help fight inflation and reduce the burden of taxation on the American people. I am pleased to be a cosponsor of H.R. 7655 which embodies principles that have received my support since my election to Congress. H.R. 7655 not only increases after-tax incentives for all individuals but slows the growth of federal spending. In addition to providing a 30 percent tax cut in three years, this legislation would begin to adjust - or "index" - all tax brackets in the fourth year according to the Consumer Price Index. This will prevent taxpayers from being pushed into higher tax brackets without increases in income. This bill also provides much needed tax incentives for business by accelerating depreciation rates for business investments. As you know, I have continually fought for legislation to limit the amount of taxes we are forced to pay. For too many years, individuals have been relentlessly pushed into higher tax brackets regardless of whether their earnings increased in "real" terms or merely because of inflation. Only through reduced levels of taxation will our society again see the beginning of real economic growth, productivity at work and increased savings. The wealth of our nation is created not only from natural resources but also, and more importantly, by people responding to economic incentives. The poverty of a nation is the result of a lack of these resources and of people being discouraged by lack of incentives to realize their full potential. When we are urged to make money, only to discover that the government will permit us to keep less than half of it, we are disinclined to do so. It is time to end the circular process of raising tax rates, economic decline, widening deficits and further tax increases. I firmly believe we must cut tax rates beginning in 1981. My support for this important legislation is not only to return to work those millions of Americans who have lost their jobs in this unnecessary recession. We must restore permanent incentives to provide the climate of lasting prosperity we need to get our fiscal house in order to meet the many challenges facing us at home and abroad. With kindest regards, I am https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Sincerely, DON RITTER Member of Congress • 4 • •• v Govi- BOARD Dr DM./ERNORS r'" FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20551 PAUL A. VOLCKER EHAIRMAN October 20, 1980 The Honorable William Proxmire Chairman Committee on Banking, Housing and Urban Affairs United States Senate Washington, D.C. 20510 Dear Chairman Proxmire: Thank you for your recent letter that includes corr espondence from Mr. Milton Schmidt concerning the Bank of Sturgeon Bay in Sturgeon Bay, Wisconsin. The facts outlined in his letter indicate that he entered into a mortgage contract with the bank in 1972, with a disclosed interest rate of seven percent. Subsequently, he was informed by the bank that the inte rest rate would be raised to eight percent, pursuant to a provision in the mortgage note which he signed. At the time Mr. Schmidt signed his mortgage, the Board's Regulation Z (Truth in Lending) gave creditors an option in dealing with contractual variable rate provisions for purposes of required disclosures. Creditors could either (1) give cert ain variable rate disclosures as part of the Truth in Lending disc losure statement that is provided prior to consummation of the cont ract or (2) make no disclosures on the disclosure statement prov ided at consummation and treat each rate increase as a refinancing of the original contract requiring a full new set of disclosures. Effective October 1977, the Board amended Regulation Z to require certain disclosures in connection with any contract cont aining a variable rate provision. Mr. Schmidt's contract was signed in 1972 and his bank can properly operate under the pre-October 1977 rule s outlined above. Evidently the bank chose to treat each rate increase as a refinancing subject to new disclosures. The new disclosure statement Mr. Schmidt received in the mail appe ars to be the bank's effort to make the required new disclosures for the rate increase. Mr. Schmidt also indicates that the variable rate clause may have been added to his contract after it was signed. This of course raises an issue of fact that we are not able to resolve. I trust you find this information useful. WiC01081040t (tv-3711) 9 Mehl* tensor SUalersii (I) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Sincerely, S/Paul A. Volcker. BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. 0. 20551 PAUL A. VOLCKER CHAIRMAN October 20, 1980 The Honorable Henry S. Reuss Chairman Committee on Banking, Finance and Urban Affairs House of Representatives Washington, D.C. 20515 Dear Chairman Reuss: Thank you for your letter of October 2 regarding implementation of the Monetary Contro l Act through Federal Reserve Regulation D (12 C.F.R. 204). You expressed concern that the provisions of Regulation D could unnecessarily subject credit uni on share accounts to reserve req uirements because, under the def inition of transaction account, routin e distributions of Federal gov ernment employee salary allotments directed to savings accounts could cause the accounts to fit within the definition of "transaction accoun t" and thus be subject to reserv e requirements. This problem has been considere d recently in light of the concerns which you and oth ers have expressed about the impact of Regulation D on the type of plans offered to customers of fin ancial institutions which have the effect of encouraging thrift amo ng depositors. We have concluded that where a deposit is made direct ly to one account, but within a very short time routine disbur sem ents of a portion of a payroll dep osit are made to family member acc ounts or other accounts of the dep ositor, such disbursements are an element of the deposit transa ction and are not to be regarded as "transfers". Thus, the capabi lity of a depositor to distribute funds in this manner would not in and of itself render an accoun t to which the payroll funds are initially deposited to be a transaction account. We feel that the above positi on clearly affords institutions the flexibility to contin ue to offer plans which encourage savings and also achieves the objectives of the Monetary Control Act by applying reserve requir ements to accounts used truly for transactions purposes. silho101hOt (rwArts) 444.4 mi4 Wimimmppoi act Sibmists Pa*, sloWasdi (2)./ 1064,44 ammode https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Sincerely, stag Action assigned Janet Hare WILLIAM PROXMIRE. WIS., CHAIRMAN II.PRISCP4 A. WILLIAMS, JR.„NJ. • ALIN CRANSTON, CALIF. ,ADL.AI t. SIVVE-N:0?4, ILL. JAKE GARN, UTAH JOHN TOWER, TEX. • POSERT •H1FIGAN. N.C. DCIEALD W. RIEGLE. JR., MICH. HE'Na. PA. WILLIAM L. ArimSTROP)(1, COLO. NATOCN LANDON K .185E1:DAUM. K AN s rAut A. RICHARD G. LUGAR. *10. JOHN SAT:RANT S. MO. DONALD W GEORGE 1 STEWTRT, ALA. 'afnifcb MITCHELL, MAINE KTNNCTH A MC LrAN ?RECTOR M. DANNY WALL, MINORiT' STAFF DIRECTOR MARY FRANCES OE LA PAVA, CHIEF' CLERK r5f3cna1e COMMITTEE ON RANKING. HOUSING. AND URBAN AFFAIRS WASHINGTON. D.C. 20510 September 24, 1980 Honorable Paul A. Volcker Chairman Federal Reserve Board Constitution Avenue between 20th and 21st Streets Washington, D.C. 20551 Dear Chairman Volcker: I am enclosing correspondence from a Mr. Milton Schmidt of Sturgeon Bay, Wisconsin who has brought to my attention a problem he has encountered with the Bank of Sturgeon Bay. Would you please review both the documents and the procedures utilized by the bank in this case and issue a statement on your inquiry as soon as possible. Best wishes. Sincerely Ns') Chairman WP:lgj Enclosures https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis L; • •••••••, 1...4•40 C•• % c`;t) :•"• • FROM THE LIOK OF 111 la • 1. , MILTON "BUD" SCHMIDT , SA, ••• 4" •••••••• -1998,Hwy. 42-57 Rt. 2 STURGEON4Ag• pl.SCONSIN 54235 PHONE 743-6966 S, 11••1•• •••.111011 ' ,•(•V•••••j11° •••.: --- • • A •-•%4* •••./ •Ir• 3, -, 3 1 ••••.11 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ..,"nator - T-12_1ian 52:41 _24rksen ...-ashin:ton, D. C. 2010. Lr -,ena„o_ • - • • .1. 7-4 led to you on _"tt"to on additi in is r lette wit;:i the --01 - of the .roble:: T v.71 L, to the Truth Stur-eon T.ay at Stur-con flay, :;-1.sconcir. 7:ith reference jusu rec.-33.-.-ed the enclosed co-r7 of a in Lendf_n2 D4 scl °sure rorn. foni fro:. the bank ne-w1-.- nre-1,,,•:d Truth in letter an or raG 04.2.000 40 c 0: c• t a.3-s•am. L. • • r• letter to us 172Z dated I.u7ust 27, 1950 not - forn the new Truth in Lendin:, a this,undotec11;-, was the •date • • P,n 1 •••. is ce_‘••3212...ely a violation of the Truth :cared.••••••-• La; and wo-ld greatly an7reciate your investigating 25, 120 lett.';r to you. it is w-,;,11 (Tar u this n -.7_012.----_cn of the "d"-al -r.- th in I(Inding la-.:s but also Trr.th :_n — viol at'- n of t:,10 rn• 4 - ••••••-• • 1 C.1 111:- • •• •-•••..) • ••• C...4.4 1 r•-•14••••• 7 , r" - r• I ....Sr •••• - 2 :1.ton "2,ud" .;ch:r.idt -'p.- ..- L. "We Live and Work in Beautiful Door County, God's Country" https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • LOCATIONS TO SERVE YOU MAIN OFF/Cl 215 NORTH THIRD AVENU1 STURGEON BAY, WISCONSIN 5423 PHONE: 414-743-555 SERVING DOOR COUNT' SINCE 188 August 27, 1980 Mr. Milton W. Schmidt RE: Mortgage Escalation Dear Mr. Schmidt: Chicago's letter Pursuant to the Federal Reserve Bank of the additional disof August 22, 1980, we are forwarding to you of Regulation Z. The closure required under section 226.8(b)(8) s the anticipated prinenclosed Truth-in -Lending statement indicate and, calculating the incipal balance due for your October payment your loan, it also terest rate to be applied on the balance of monthly payment. This shows the total finance charge as well as the State disclosure requirestatement complies with all Federal and usion or misunderments and should avoid any possibility of conf have any questions, standing in the future. However, should you please feel free to contact me personally. Verj trul yours, Steph n A. Kas Corporation Co nsel 31K: Lm Enclosure CC: Ron Berg Tom Herlache Federal Reserve Bank Removal Notice The item(s) identified below have been removed in accordance with FRASER's policy on handling sensitive information in digitization projects due to personally identifiable information. Citation Information Document Type: Personal account documents Citations: Number of Pages Removed: 2 Mortgage loan disclosure, Bank of Sturgeon Bay, May 31, 1972. Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org *• 6 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis FEDERAL RESERVE BANK OF CHICAGO 2 It)' , SIKH- I sAl I 04I I I ('I II( ILI INt)ii, 600440 (312) 322-5322 August 21, 1980 Mr. Milton W. Schmidt Dear Mr. Schmidt: This is to acknowledge your letter of August 16, 1980. We have enclosed Federal Reserve Board staff Public Information Letter number 749, written for a situation identical to yours. Therefore, our opinion is consistent with letter 749, that is, by a contractual agreement outisde the sphere of Regulation Z, the bank is free to change the rate so long as it treats the change in terms as a ;-errifanc rig requiring new Truth in Lending disclosures. a.•• •.1.411666666666•66MInalummo A copy of Regulation Z, is enclosed. Please note that interpretation 226.810(page 76) has been superceded by Section 226.8(6)(8). Very truly yours / (7 ohn L. Bergstrom - Supervisory Examiner NOTE: This letter was just received today when we were about to nail this infornation to you. You can see our problem. Our loan on our home has not been refinanced but is the original loan as of 1:ay 311 1972 and payments have been made each and every month without fail. ilton "3ud" Schmidt FROM THE C le VII •• •. Lk'. 314 MILTON "BUD" SCHMIDT 3998 Hwy. 42-57 Rt. 2 STURGEON BAY. WISCONSIN 54235 PHONE 74,3-6966 Li 1 4',•1 1;st 25) 1930 ACAW.A.011, c 1••••:* 1.• OF 4, Senator illian Pro:=..re) 52/41 air::sen Duilc:Lnr, :•:[.-.sh.ington, D. C. 2051(..). Dear Senator Proxmire: forn !. natter has arisen with reference to the Truth in L3nding Disclosure with w:lich my .J - n and 1 signed when we no2tgaged our hone on !:ay 31, 1972 the Dan:: o2 Sturr:eon ray at Sturgeon 3ay, 174sconsin. would be The ban:: sent us a notice on June 23, 1930 stating our interest rate increased fron 7 to 6. (,ur r1ruth in Lending form did not specify that there would be any increase in interest at any tine. It clearly specified that we wood have 2'L40 consecutive 7aynents at U2h.05 per Eonth, at 75 interest, with It no indication of any further paynento or possible increases in the future. this form. is our understanding that any escalation clause must be also noted on . at rninterest, we would not have signed the t:e :mown there .--_, be an increase in well form or t.,":nn the nort7a:e from then. :L copy of this form is enclosed, as • letters to us. as enclosed is a co-.7 of the mortr:age note which we signed. Kowever, we would we like to 7c'nt out that we did not receive a co.:7 of this note at the time the mort72.7-. This co:7y •Tne. made for us at the bank just a few days ed cur request. -0 also wish to point out that the mort:2.70 note indicat we have no ::nowled,7e tend was ty-ped on an escalation clause was added of which would the r07nrsn side of the note. Ka0 we ::nown this at the tine in 1972, we date by not have signed the note. This addition :lay have been added at a later disclosed the bank. ':e ha7e no way o2 ::nowin:2, but one thing is sure, it was not notice, on to us or reflected in the Truth in Lending Disclosure form. If you were crossed the Truth in Lendin2 for.: under "::ortgage Costs", additional char:es to know what o:: because we would not agree to any additional charges. 7e wanted our e;:act costs would be at the closirr- as well as in the fliture. 3D ca is legal. checked with the :ederal Reserve Earl:: in M,ica7o, and they said this for a I:owever, we do not feel it is legal—otherwise there would be no reason a waste of "ruth in Iondinr: form and the form is definitely then worthless and taayer's money. 7 2- 1980 do not feel an e. andly investi7ate this matter and advise as soon as possibl in Lending increase in interest is warranted since it did not a712ear on the Truth feel this is a violation of the Truth in Lending regulation. Disclosure form. dum YG0152. 1-lnase refer to :leguLAion Z 226.8 (B) (8) 12/27/78 and also memoran Thank you very n7ach for your heln. 1'OT7: https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis T :mow I can count an your assistance. See notation on bottom of 7ederal I:eserve Dan: letter dated Aug. 21, 1930. Yours very, "We Live and Work in Beautiful Door County, GM A 4<Q I CY-ur7Try F 5 -L^-42 C https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • LOCATIONS TO SERVE YOU MAIN OF,FICE 2 1 5 NORTH THIRD AVENUE STURGEON BAY, WISCONSIN June 23, 1980 54235 PHONE: 414-743-5551 SERVING DOOR COUNTY SINCE 1889 Mr. and Mrs. Milton Schmidt Dear Mr. and Mrs. Schmidt: As we all know, spiraling inflation is making everything more expensive. The cost of money is no exception. As you may recall, your mortgage note with the Bank of Sturgeon Bay contains a clause which permits the Bank of Sturgeon Bay to escalate the interest rate under certain circumstances and after proper notice to you. °thy' finarwial tw:litutions hAve long been invoking the escalation clause but until recently the Bank of Sturgeon Bay has been able to Recently, inflation has become so severe that the avoid doing so. Bank of Sturgeon Bay has been compelled to increase its interest We regret that this action has become necessary. rates as well. Attached to this letter is the official notice required by the At the Wisconsin Statutes advising you of your rate increase. time your new rate becomes effective, you will be sent a new Please read the notice carefully. If you have any payment book. questions, please feel free to contact our Mortgage Loan Department. Sincerely, Ronald D. Berg Vice President RDB:nad Removal Notice The item(s) identified below have been removed in accordance with FRASER's policy on handling sensitive information in digitization projects due to personally identifiable information. Citation Information Document Type: Personal account documents Citations: Number of Pages Removed: 5 Notice of interest adjustment, Bank of Sturgeon Bay, June 23, 1980. Mortgage agreement, Bank of Sturgeon Bay, May 31, 1972. Mortgage note, Bank of Sturgeon Bay, June 30, 1972. Payment record, undated. Mortgage note, Bank of Sturgeon Bay, June 30, 1972. Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org VdidcoL, 11- 3 er October 22, 1900 iTIlemorahist Daniel K. Inouye United States Senate Washington, D.C. 20510 Dear Senator Inouye* Thamk you for your letter of October 18, 1980, concerning the requests al mommember depository institutions in Rawaii for temporary relief from Federal reserve requirements under the Monetary Control Act of 19$0. Yesterday the Board oomsidered thee* requests and determined that a six-month waiver of reserve requirements until May 1981 in approporiao for seamember depository institutions in Bassaii that are not currently :equired to maintain reserves under the Act. The Board's action was taken after examination of the legislative history the exemption provided by the Act for certain State-chartered inatitutioms located in Hawaii amd in view of the small amount of reserves that otherwise would be required to be maintained. It is anticipated that the board's action will provide Congress with an opportunity *ally next year to re-examine the extraordinary exemption for institutions located in Hawaii. In order to assist the Board in obtaining data necessary fim the conduct of mometary policy, all institutions in Bioeli are requested to grapes* and file the Federal Seserve's report of deposits form in aceeedamcor with ftgalation D just as is requireW of ell of the nation's dOPOsitory imstitettems. The Board appreciates your interest in this matter and having received the benefit at your vises. Sincerely, Wail!A, VOldiel GTS:bbo 10/22/80 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis CiffAirei.Las MC C.14Airmur_As 9 JR. inviirEno STATES SATE October 27, 1980 Dear Paul: Thank you for your generous letter regarding my recent foreign policy statement. I appreciate your taking the time to share your thoughtful comments with me. With best wishes, Sincerely, Charles McC. Mathias, Jr. United States Senator Honorable Paul A. Volcker Chairman, Board of Governors of the Federal Reserve System 20th and Constitution Avenue, N.W. Washington, D.C. 20551 Octo!-er 27, 1'.381 The Uonorable Wi1lie Prox-dro e%airman Committee on Tie.r.%in, and T2r;,:ca1 Aifaira kinited Statoe Oenete Waah1nct4>n, r.c. 20510 Deur Chairman ProxrAro. l'ou *tor your lettcr of f.,ctoi er 22 re:con:lending Ilarren L. Lri s, ft z.NoloZ of ttc Conruner 70visory Council. 1 c:an assmre you that :iernite quzilifications will receive full consideration when tif? roar.f! oakef. tLo lrtEl aproint ot%nts to tLe Thg Doara amreciates receivitsg youx recmnemlation and your intar -t in the C .insumer . AdviE.ury Council. Sincerely, CO.* t (#V-402) bcc: Ann Marie Bray (w/co;yy of incolainq) rIrs. nallardi (2) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis WILLIAM PROXMIRE. WIS., CHAIRMAN HARRISON A. WILLIAMS, JR., N.J. ALAN CRANSTON. CALIF. ADLAI I STEVENSON. ILL. R0DERT MORGAN. N.C. DONALD W. RIEGLE, JR., MICH. PAUL S. SARDANES, MO. DONALD W. STE WART. ALA. GEORGE J. MITCHELL, MAINE JAKE ()ARM. UTAH JOHN TOWER. TEX. JOHN HEINZ. PA. WILLIAM L. ARMSTRONG. COLO. NANCY LANDON KASSESAUM, KANS. RICHARD G. LUGAR, IND. KENNETH A. MC LEAN, STAFF DIRECTOR M. DANNY WALL, MINORITY STAFF DIRECTOR MARY FRANCES DI LA PAVA, CHIEF CLERK ?JC-niffb Zfatez „Senate COMMITTEE ON BANKING. HOUSING. AND URBAN AFFAIRS WASHINGTON. D.C. 20510 qv October 22, 1980 dad) Honorable Paul A. Volcker Chairman, Board of Governors of the Federal Reserve System Washington, DC 20551 Dear Chairman Volcker: I write to recommend the appointment of Warren L. Dennis to be a member of the Board's Consumer Advisory Council. Mr. Dennis has demonstrated exceptional knowledge and an exceptional record of accomplishment both in his prior work with the Department of Justice and his more recent work with the firm of Troy, Malin and Pottinger. Mr. Dennis has substantial expertise on the subjects of the Equal Credit Opportunity Act, Fair Housing Act, and Community Reinvestment Act. I am sure that he would be a valuable addition to the Advisory Council. crel tTlim Chairman WP:srj https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis re Octot'er 27, 1980 The Honorable ii1ia Proxmire CLairman Committee on Sanl‘imi l Rousing and Url,an Affairs United States Senate Washinvton, D.C. 20510 Dear Chairczan Proxmire: Thank 'feu for your letter of Octol-er 10 in you encloae cerrc!niondence froL t'r. and Mrs. Uilfred Reiting concerninii tLa eTilication of !Judson Bancsharen Ccrporation for Board aproval to becorie a Lank holding company. r. one, Heitinq have beer contacted Ly the Federal Raucrve Lank of einneai.olis and advised that tho aprlication has been acccrted for irocesAing by the Poser,' Notico of tIm application has been puLlished ir t.e Federal Pe7ister and the cloce of the uublic comment period as set fcrth In the Federal le0.stta. is Lovember 3. Any further cormemts that the Haitin9s have concernin tle application ihould be submitted by that date. Sincerely, Saaglitygidig ItML.DaW:pjt (#V-392) bcc: Mr. Mannion Mrs. Lallardi (2)t./ Legal Eccords (2) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis WILLIAM PROXMIRE, WIS.. CHAIRMAN HARRISON A. WIL IIAMS. JR.. ALAN CRANSTON. csur. ADLAI E. STFVENSON. ILL.. ROOFRT MORGAN, N.C. RI! GLE, JR.. MICH. DONALD PAUL S. frotnnimirs. MO. DON•LD W STEWART. ALA. GEORGE J. MITCHELL. MAINE JAKE DARN. UTAH JOHN TOWER, TEX. JOHN HEINZ. PA. WILLIAM L. ARMSTRONG. COLO. NANCY LANDON K A SSERAUM. KANS. RICHARD G. LUGAR. ONO. KENNETH A. MC LEAN. STAFF DIRECTOR M. DANNY WALL, MINORITY STAFF DIRECTOR MARY FRANCES DE LA PAVA. CHIEF CLERK https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ?Artifeb Zfatez --Senate COMMI T TEE ON BANKING. HOUSING. AND URBAN AFFAIRS WASHINGTON. D.C. 20510 October 10, 1980 C ,r1 The Honorable Paul Volcker Chairman Federal Reserve System Washington, D. C. Dear Mr. Chairman: I have enclosed a copy of a letter with attachments from Mr. Mrs. Wilfred Heiting regarding the application of Hudson Bancshares Corporation. I would appreciate it if your Office or the Federal Reserve Bank of Minneapolis would contact the Heiting's about this matter so that they may be fully heard. Thank you in advance for your cooperation. Sincerely, l e • 'William Proxmire Chairman WP:lmg 4 • Septem er 14, 1980 69.FTPAP :1',1.1 14: 52 i3' Hon. William Proxmire United States Senate 5241 Dirksen Senate Office Building Washington, D.C. '20510 Re: Application of Hudson BancsNires Corporation Dear Senator Proxmire: The Hudson State Bank was organized in 1968-69 with the help of approximately 300 local middle class people who saw a need for a second bank in our community. It was truly a people's bank until the enclosed letter went out to the share— holders in late June. We are still in shock. Some of us asked for a courtesy meeting where we could learn about the "changing priorities" mentioned in the letter. This has not been granted. We have also appealed to the Federal Reserve Bank of Minneapolis, and we are informed that our only opportunity to participate in a hearing would be after notice is given in the Federal Register and that is only a faint possibility. During the years when the bank was growing, we were thanked profusely and praised for our support. Suddenly the sweet—talk has stopped, and we are left trying to figure why we are suddenly dispensible. Our question at this time is: Federal Register? https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis How do we become aware of the notice in the Could your office help us? We thank you for any assistance you can give us, and for all past work on our behalf. Wilfred G. and Catherine B. Heiting • 4 STP.,T.E..A.N1( of HUDSON — tc: .5 3 Dear Stockholder, Changing priorities, interests and personal needs of same of our major State Bank of Hudson stockholders have brought on a number of requests for sale of their stock. In an effort to retain local ownership and current bank management, staff and philosophy, Glen Gaynor, Richard Kenall, David Cleveland and Darrell Youngberg have agreed to purchase controlling interest in the bank. No other agreements with any individuals or holding_ganpanies to sell the banks controlling interest shares have bccn made or are (nticipated. , This letter is an offer to purchase all of your State Bank of Hudson stock at $130.00 per share. Current book value for your stock is $120.00. This offer to buy your stock is made to you contingent on; A.) Your tendering of all of your shares, B.) Buyers ability to buy no less than 80% of all of the outstanding shares C.) Buyers ability to gain approval from thejederal Reserve to form a one Bank holding oompany) The buyers have the right, but are not obligated, to purchase more than 80% of the outstanding shares. In the event that more than 80% are offered for sale, 80% of each individual's share holdings may be purchased on a prorata basis but in no case will the 20% remaining unsold be faxer.than two shares. The buyers do not anticipate any future offers to purchase minority shares. Your acceptance of this offer, in order to be valid, must be signed and returned to Darrell Youngberg, at his State Bank office, on or before June 20, 1980. Upon acceptance and if the other conditions of the offer are met, we anticipate finalization of purchase and payment to you on or before September 15, 1980. An offer to purchase is being made to all State Bank of Hudson shareholders. Please direct any questions you might have to any of the undersigned. GlIç. Gor Richard Kemal Darrel R Youn 4w,g David E. Cleveland e to sell all of my (our) State Bank of Hudson stock pursuant to I (we) the above provisions. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 715'386-9366 • 600 SECOND STPEET, HUDSON, WISCONSIN 54016 c\GLA-L.•7_ E.-k C:7-"I k \A aL.N.N...\.k 1110 During July, 1967, a group of nine local businessmen met to discuss the feasibility of a new financial institution to nerve the Hudson area. From that meeting came the basic philosophy that has guided the incorporators during the past eighteen months in the development of the new State Bank of Hudson. 1. That the bank be locally owned. 2. That the ownership be spread among as many stockholders as possible. 3. That the best possible location be used. 4. That the best possible facility be built. 5. That services be provided the community which are not presently provided. These guide lines have constantly effected the decisions of the incorporators. Three of the incorporators were present at that original meeting - James V. Hirsch, G. Fred Kremer, and Richard N. Larsen. Monthly meetings were held from July through December. Subscription agreement was circulated through out the area to assess public interest. The community showed $400,000.00 worth of interest without making the subscriptions a public issue. In January and February the bank group met weekly at breakfast meetings, some as early as 6:30, with Attorney John Bosshard of La Crosse, whom the incorporators hired to provide specific legal counsel. All of these meetings were pointing toward State Banking Federal Reserve Board and FDIC approval. In March, Mr. Hirsch, Mr. Kremer, Mr. Dabruzzi. and Mr. Larsen flew to Madison to set up a hearing date before the State Banking Com issioner. • In April, each of the incorporators submitted to a lengthy examination given by the FDIC and Federal Reserve Board. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 6422\ S • S • The hearing, which was contested by the other local banking facility, took place in May at Madison. Preparations for this meeting included the proposed facilite-., area growth potential and financial needs and expected growth of the new bank. The State Bank of Hudson became a reality as the information given by the incorporators convinced the banking commissioner of Hudson's need. In June, the incorporators elected officers from the group. President- G. Fred Kremer, Vice President - James V. Hirsch, Secretary - Richard N. Larsen, Treasurer - Glen D. Gaynor. The incorporators have met each Tuesday evening since June, assessing building plans, selling stock and the thousand and one things necessary to the formation of a new business. In March, an option was taken on the Wichser building and purchase was completed on October first. Construction on the new building began November first and will continue throughout the winter. The new building will be completed by June 16, 1969, almost two years after the original meeting. Stock sale began in September of 1968, and the goal of $400,000.00 was reached e-t-ct4: 1-- 7-,rie)• 23‘ -Y ..e by December 16, 1968. 13,4 y •4 4.4. 9148 man hours have been spent during the past 18 month Bank of Hudson to its first Stockholders meeting. P G- „cc. A to bring the S+'"7 ' ' It would take one man working 40 hours per week almost five years to amass 9148 hours of labor. On a basis of $4.0n per hour, that man would have earned $36,592.00 during this five year period. The incorporators have received no payment for the time spent and the various trips and meetings have been held at their own expense. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 4 Removal Notice The item(s) identified below have been removed in accordance with FRASER's policy on handling sensitive information in digitization projects due to copyright protections. Citation Information Document Type: Advertisements Citations: Number of Pages Removed: 2 The State Bank of Hudson. "Hudson's Community Owned Bank." Undated. Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Tvv Aouora43.e IlaAat L. Auli.a :i.amwa of ,:kseTrosontativez Ikusnire)ton, f;.C. 24SV4 !7'eftparitaa /04anik you for 1-givitt tt-it OirtkArity t refwzr,4 tc L_A„. liavefA tter trotk your covo*titmiczti 11P. 3:i Iar NiN ;47o“oita1s are 1nteroatir4 aad irmovative, IL :Act, ,seveielle Coirrou;:ordonco bollworm gr. 0A4 Zi4ax, 4144 C1, 4aixzen gillor bats addrosswe the work -chiming ;IAr, Oise eaelesaces). views on this prcirosol aro essentially the 10A60 th**0 Almq.x016411ed in th. ea:tiler corraswondencs. /ft addition e I would mots that several inatitetionA aro experivettiAii viez loam, of the equity-sharinv ty:As that r. St4rl. ,Trokoaes, rtAx; t.44* offered is(.;xe 0..)tIsttrb.ctive idcos; ho,,mvore I .AaJovr . e tLiot iAnat.korsar!i 1.,re,Asoro* aro co 44q4pty ontriereo4, tJ4it a .404Ador-Laotbd “Aicy rospormo 1* reNu1rc4. 41:.ropriste and kerAiete:4t o4tiorto t:Ap VtVeCAmOrte. i co*ratic,a vitt *rforts 441044 labor, should result ovityr tiae in a groduoi ttidtn douu of ifttlation an4 a ri4o in 10..4) levol tt av,loyment. 2 van zi4ire 10U tat rslobotary 0Aiicy iA i&inrotlucteel "'its toot c4./jzzctAvoz ta ;74nd. - A. IluiL;44 - (Mr. dtd. 10/23/78 4 9/29/72 fror4 niller to Ca Enar15; and ltrs. dtd. 10/13/79 4 7/5/78 from the arott to ClIrtan. ;.1110:J2.DJ4p eljt (M385) ;r. KicEline https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis liCtriey 1-ta11ardi (2)-0' Alction assigned Mr. Kichline A1 . 3 "ALCI SERVICLS COMMITTEE 4 sutscommiTTE(S PROCUREMENT AND MILITARY NUCLEAR SYSTEMS WASHINGTON OFFICr: 1108 LONG WORTH HOC'S E Orrper Buitointo WAsmimcToN. D.C. 20515 (202) 225-5611 INVESTIGATIONS Congre55 of die artiteb *tatc5 HOUSE ADMINISTRATION COMMITTEE ji)oruSe of ikeprefSentatibei4 SUBCOm hi ITT FES' OFFICE SYSTEMS ACCOUNTS DIST RICT OFFICE, 1649 WESTCLIFF DRIVE NEWPORT BEACH. CALIFORNIA ROBERT E. BADHAM 40TH DISTRICT. CALIFORNIA October 2, 1980 The Honorable Paul A. Volcker Chairman of the Federal Reserve Board Washington, D.C. 20551 D2ar Chairman Volcker: Enclosed is a letter that a constituent of mine, John Sharp, requested I bring to your attention. Mr. Sharp outlines a proposal to reduce inflation and employment at the same time. It would be appreciated if you would carefully consider this proposal and share with Mr. Sharp any comments you may have on it. Cordj,belly, .2 ., / i 1 / i, E.`Badham Member of Congress /Robert REB:cmw cc: https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. John V. Sharp (714) 631-0040 92660 3015-N Via Buena Vista Laguna Hills, CA 92653 September 15, 1980 The Honorable Paul A. Volcker Chairman of the Federal Reserve Board Washington, DC 20551 Dear Chairman Volcker: You have again shown how to cut our inflation rate. Your action, as you know, would save about $25 billion for each 1%-cut you achieve this year. Yet Senator Cranston, while visiting Leisure World in July, said "Congress would lose about $25 billion for each 1% rise in unemployment". Consequently, will you please consider a set of legal provisions--similar to ones used in California and elsewhere. A review of the legal status of similar provisions is as follows: g Credit-sharing loans --started by your policy letter of 8/23/79. • Work -sharing compensation --started in California in July, 1978 by Senator Greene of Watts --a former union official. Its success now leads Congresswoman Schroeder to extend th-T —law nationwide. • Equity-sharing loans --issued in California to defer senior homeowner taxes, and elsewhere as mortgages for new-home buyers. 9 Rent-sharing agreements--to pass through cuts by Proposition "13". Extending this set could cut inflation and unemployment together. How? Each employer who uses bank loans could prepare a plan using these provisions. By his plan he could reduce spending to hold down prices, yet avoid lay-offs during severe regional downturns only. Tax, union, and rental officials could approve when needed. The set of provisions which any regional employer could use, are: s Credit-sharing loans--with reduced purchases and inventories. o Work -sharing compensation --with reduced payrolls and no lay-offs. a Equity-sharing loans--with reduced mortgage repayments and taxes. o Rent-sharing agreements--with reduced rents paid to owners who choose to participate as employers or employees. My a e a convictions about the use of these cost-effective* provisions are: Related laws with incentives can be promptly extended nationwide. Fewer lay-offs and equitable income-sharing could result for all. You could then cut both inflation and unemployment less painfully. Accordingly, will you and your regional bankers consider giving the legislative push, plus the administration, needed to combine the provisions into "A National Downturn -Sharing System"?(1) By contrast, is not income -indexing really upturn sharing? Will you then favor me with a critique of this policy to share with its many contributors? Productivel yours, 2, Ref. (1)--details, if you wish. ) (John V. Sharp (*)-All reductions are in 5% steps--set by the percentage a region's downturn exceeds the nation's during the three preceeding months. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20551 PAUL A. VOLCKER CHAIRMAN October 27, 1980 The Honorable William -Proxmire Chairman Committee on Banking, Housing and Urban Affairs United States Senate Washington, D. C. 20510 Dear Chairman Proxmire: Thank you for your letter of October 9 inquiring about the legality of the Citi-Shopper customer discount service that is being promoted by Citibank. Citi-Shopper is a merchandising service offered to holders of Citibank credit cards by Comp-U-Card, Inc., an organization unrelated to Citibank. Although this service does not appear to violate Regulation Q or give rise to consumer problems, I have asked my staff to review this matter in more detail. In addition, because Citibank is a national bank and as such is under the jurisdiction of the Comptroller of the Currency, I have also referred your request to the Comptroller for respo nse. Sincerely, cc: Congressional Liaison Office Office of the Comptroller of the Currency LSA:vcd (#V-390) bcc: https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Lee Adams (for follow-up) Mrs. Mallardi (2) •-e". ••••••••••il...1. p 1A1PI. --014 A. WILLIAMS. JR.. N.J. ALAN Cf.,van-roki. C.ALir, AM. A I I STEVENSOP . ILL. ROM RT MoRGAN. N c. fl(NAI r FC.( r. JR.. MICH. rAUL c sA.HA, ./ c. MO. DONNt U A STF WART, ALA. Action assigned Gil Schwartz *coordination with Janet Hart's Division • NILE IAM PROXMIRE. WIS., CHAIRMAN JAKE GARN. UTAH JOHN TOWER. TEX. JOHN HI INZ. PA. WILLIAM L. ARMSTRONG. COLO. NANCY LANDON I ASSERAUM. KANS. RICHARD G. UJGAR, 1110. Zfalc,c; Zenate GEORGE J. MITC14 , LL. MAINE KENNr Fit A. MC Li H. STAFF DIRECTOR H. CANNY WALL, MINORITY STAFF DIRECTOR MARY FRANCES DE LA PAVA, CHIEF CLERK https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis COMMI I TEE ON BANKING. HOUSING. AND URBAN AFFAIRS WASHINGTON, D.C. 20510 October 9, 1980 Honorable Paul A. Volcker Chairman Federal Reserve Board Constitution Avenue between 20th and 21st Streets Washington, D.C. 20551 NJ Dear Chairman Volcker: A considerable number of constituents have expressed concern that a new customer discount program initiated by Citibank, known as "Citishopper", may include several anticonsumer elements. I would appreciate it if the Board would initiate an investigation of this program to determine whether it complies with all applicable federal and state laws and regulations. Best wishes. /William Proxmire Chairman WP:lj J. .44)-•nL,:ttt NItritoti -Jaited St44tos 4olsati4 usahlregtort, 2051C Johustov :jou 1:or four lett4r of c.tor-(!x- 8 rccovend, Tbo44ob C. &afford; be considered for af..1.ointlAtint et a rireetor of the 1.410 OrIeens Urine!, of the Fe(loral '-v4orve Szink '‘tlanta. T444 ked*ral reserve /* vigry race, ir,tareetifd ift ts104nte4 frOM 4 Wide Yarittt Of hactitounds for l4)vci'1,i4 tirvletl. se r(rgervs rcctors. We z1a11 Nt. Jeffrey's naime in 4:1.rci AS 4 rolvible candidate for IVIt .;:t1v4 OrloAats :Irtmch Ipcitsd 4 taad your ritcei3(!Ation hos sloe bosh iat, 11141ta Y. nrd, PresVel-J7it of tc r4ro1 ret!srvc, AtIaot4i4 for coseideratim of Jeffroy 4t1 & a -t1r-vt,, Uan) Droctor of the,. Vow OrIvan I 4i::pr(A:itte yout intercat in ideztifyinr4 - usliffed fcir :1-0tAttz-ve 10.ank Directors. Pi!;cerel s . WUW:DSWt (4V-387) bcc; Ford—Ma, Atlanta r. Wallace nrs.fla11ardi (2) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis JA.CPRON, WA I Aro'C C$411FM'N. IDAI!O JOHNFTCN, LA. J. [IF' DALE et wprrel. AF.K. %VFW:1UL N. FORD. KY. JC.NN A DurtviN. N H. SFAR`C M aiktimikm MAF/K 0. HATFIWLD. OREG. JAP..5 A. AC cLu.m. toA),o MrTZE-NrAUNI. OHIO 1...ATCUNAC:A. NAWAU LOWF EL P. WFICY.ER. JR.. 4 Mr rot V. DOMENIC!. N. MF.X. TFD ST-Tvrus. ALA6KA 14I- NRY elit MON, 04.L.A. MALCOLM WALLOP. !MVO. JOHN MEI. r.-14, R. MON'''. PAUL W. Tsorrskc. MAAr RR.% IWADCF.Y. N.J. vry-pw tion assigned Bill Wallace ?-1G-tifeb ,,T)fafez Zertafe COMMITTEE ON ENERGY AND NATURAL RESOURCES DAN;EL A. DPFVFIJI. ATAFIF cinrc-rort D. MICN - In NARVIY. couronri iper.rw SAY DIRIELTOR FOR Tlif MINcAtr-y https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • WASHINGTON. D.C. 20510 October 8, 1980 The Honorable Paul A. Volcher Chairman Board of Governors Federal Reserve System Washington, D.C. 20551 Dear Chairman Volcher: I am writing to bring to your attention the candidacy of Thomas C. Jeffery for a Class C Director position in the New Orleans branch of the Federal Reserve System. While I am not personally acquainted with Mr. Jeffery, I have been impressed with all that I have learned of him from the Managing Director of the Louisiana Credit Union League, whose organization has nominated him for this post. Mr. Jeffery has long been active in the League as well as in his own credit union. He has played a very important part in initiating programs at both levels and has been recognized, in particular, for the job he has done in heading up the League's Legislative and Government Affairs Committee and chairing the Student Loan Program Committee. Because the Federal Reserve is now beginning to regulate some of the programs sponsored by credit unions I'm sure that persons representative of these organizations will soon be made a part of your agency. I know that Mr. Jeffery will be one to whom you will want to give careful consideration. With kindest regards, I am Bennett John. on ited States Senator JBJ:mm 1\\A-3 f\v‘xkt_ . 3%0 . ••0'i- o • BOARD OF GOVERNOR •P • • co , •o A • "1 • _A 'jq[1M 1 I. 1.1.s • ("0•44: . • • fRAL OF THE FEDERAL RESERVE SYSTEM L.) •• L."- • . . 4 • •• WASHINGTON, O. C. 20SSI PAUL A. VOLCKER CHAIRMAN October 28, 1980. The Honorable Russell B. Long United States Senate Washington, D.C. 20510 Dear Senator Long: Thank you for your letter of October 16, enclosing a copy of correspondence you received from First Republic Bank, Rayville, Louisiana, concerning Federal reserves required to be maintained by the Bank pursuant to the Mone tary Control Act of 1980, Public Law 96-221. As you know, Public Law 96-221 provides that a bank that was a member of the Federal Reserve Syst em on July 1, 1979, and withdrew between that time and March 30, 1980, is required to maintain reserves to the same extent as a memb er bank. Nonmember depository institutions, including bank s that withdrew from membership before July 1, 1979, are entitled to an eight-year phase-in of reserve requirements under the Act. First Republic Bank withdrew from System membership on February 1, 1980, and thus is required by Public Law 96-221 to maintain rese rves to the same extent as a member bank. In recognition that an individual bank's withdrawal from the Federal Reserve System may have been delayed by individual circumstances, the Board, consistent with the legislative history of the Monetary Control Act, on April 23, 1980, issued an interpretive ruling (12 C.F.R. § 204.120) providing that a former member bank that presented evidence that it made an unambiguous, irrevocable decision to withdraw from membership befo re July 1, 1979, would be entitled to an eight-year phase-in of requ ired reserves. The interpretation provided that a former national bank that presented the Board with documentation that its shar eholders voted to convert to a State charter prior to July 1, 1979, and that was not a member bank on March 31, 1980, would qualify for the eight-year phase-in of reserves. The interpretation stated that banks desiring consideration under the provisions of the inte rpretation should submit full documentation to the Board as soon as possible, but in any event no later than June 16, 1980. On June 17, 1980, First Republic Bank requested consideration under the Board's interpretation. The Bank supplied information https://fraser.stlouisfed.org • Federal Reserve Bank of St. Louis The Honorable Russell B. Long Page Two to the Board indicating that its board of directors did not vote to convert to a State charter unt il November 13, 1979, and that its shareholders did not vote to approve the conversion until January 15, 1980. Accordingly, in a letter dated July 17, 198 0, the Board advised the Bank that it was not eligible for the eig htyear phase-in of reserves under the interpretation and that it would be required to maintain reserves to the same extent as a member bank, as required by Pub lic Law 96-221, beginning with the seven day reserve maintenance per iod commencing on August 28, 198 0. The Board also advised the 'Bank that the Board would consider gra nting limited extensions of the time for maintaining reserves in extraordinary circumstances in recogn ition that former member banks could experience hardship by bei ng subjected to Federal reserv e requirements by the August 28 mai ntenance period. The Bank was requested to submit any relevant information to the Board before July 31, 1980, if it wished to be considered for hardship relief . The Board has received no fur ther correspondence from the Bank indicating that it wished to be considered for hardship relief. The Board has afforded to First Republic Bank the full extent of the opportunity for rel ief that the Board believes is available under Public Law 96221. While we can understand the Bank's concern, the Board does not believe that the statute authorizes the exemption from the provisions of the law that First Republic Bank requests. We appreciate your interest in this matter. us know if we can provide any additional information. Sincerely, S/Pakil A. VOcker :;'IsSeV41014 4C0,1013V1pjt .cc. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis (11V-3,4) Cil Schwartz ns, Foin mrs. talardi (2) Legal Recor40 (2) Please let ction assigned Mr. Petersen RIJSSCLL • LONO, LA , CHAIRMAN r. TALMADGE. GA. HI Apt,1,141, 44 ntoocorr. CONN. HAtt.sinf r. nrpo. JR.. VA, oArt , :nr) NrLsom. GRAVI L. ALArKA 0•0 DI NTSIN, TUX. SPAqK MATSLONAGA, HAWAII DAN•t t PATRICK MCF(NIHAN, ROBERT J. DOLC. KANS. 808 PACKWOOD, OfllitS. WILLIAM v. sto*H. JR DLL. JOHN C. DANFORTH, MO. JOHN H. CHAFIE, R.I. JOHN HEINZ. PA. MALCOLM WALLOP. WTO. DAVID DURENEILROT ?Jettifeb ,Sfatez MtNN. MAY 8AUCLIS, MONT. DAVI() L. DORI N, OKLA. WILL BRADLEY, N.J. ROM e COMMITTEE ON FINANCE WASHINGTON. D.C. 20510 MICHAEL STERN. STAFF DIRECTOR LIGHTHIEER. CHILF MINORITY COUNSEL October 16, 1980 Honorable Paul A. Volcker Chairman, Board of Governors of the Federal Reserve System Federal Reserve Building Constitution Avenue between Twentieth and Twenty-first Streets Washington, D. C. 20551 Dear Mr. Chairman: Enclosed is a copy of correspondence from First RepuIE blic Bank of Rayville, Louisiana, concerning problems they are experiencing with reserve requirements as a result of Public Law 96-221. I would appreciate your consideration of the correspondence on the matter. Thank you for your assistance. and your .i.JIsuIiLj https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis With best wishes, I am Sincerely yours /..711.0..'t•Of ,, W. D. COTTON, Chairman 01 The Board " P F. STAFFORD, President ,4747 r Fili B 0. DOX 077 / RAYVILLE, LOUISIANA 7126D iu 54 'ALTERS, Vice President 80 BY J. KING, Vice President MRS. FLORA B. KALIL, Cashier MRS. HATTIE C. EPPINETTE, Assistant Cashier ItqCY K. HARRIGILL, Assistant Cashier Zlil September 16, 1980 Honorable Russell B. Long Senate Office Building Washington, D. C. 20510 r-n Subject: Monetary Control Act ofr80 Public Law 96-221 - March 31, 1980 Dear Senator Long: On June 25, 1980, we wrote you regarding the referenced legislatila=and its impact on our bank. The specific part of the law which has such a vastating effect on our bank is Section 103(8)(D)(i), whic h provides: "Any bank which was a member bank on July 1, 1979, and which withdraws from membership in the Federal Reserve System during the period beginning on July 1, 1979, and ending on the day before the date of enactment of the Depository Institutions Deregulation and Mone tary Control Act of 1980, shall maintain reserves beginning on such date of enactment in an amount equal to the amount of reserves it woul have d been required to maintain if it had been a member bank on such date of enactment. After such date of enactment, any such bank shall main tain reserves in the same amounts as member banks are required to maintain under this subsection, pursuant to subparagraphs (B) and (C)( i)." We were formerly First National Bank of Rayville. We had been a national bank and Fed member since May, 1952. After many mont hs of thoughtf liberate analysis and investigation, we applied and were approved ul and defor a charter conversion from a national banking association to a stat bank e , regulated and supervised by the Office of Financial Institutions, Stat e of Louisiana. Our charter conversion and Fed withdrawal was effective February 1, 1980. As we informed you in our June 25th letter, we had applied to the Federal Reserve Board of Governors for an exemption from this prov ision. We outlined in detail our reasons for the request, citing the step by step process we used https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 'Honorable Russell B. September 16, 1980 .)[.1- 2? 10 s'4 AN '60 to convert our charter from a National Banking Association to a state bank and to withdraw our membership from the Federal Reserve System. Our request for exemption was subsequently denied, and a copy of the letter informing us of the denial is enclosed for your information. You will note in paragraph two of this letter of denial that a former member bank may present evidence that it mad?an unambiguous, irrevocable decision to withdraw from membership before July 1, 1979, in order to qualify for an exemption from this provision. In paragraph three, the letter states that the Board regards votes of both the directors and shareholders as necessary elements of an irrevocable decision. As we pointed out to the Board of Governors we commenced our conversion process on May 11, 1979, prior to July 1, 1979. As a matter of practicality and priority, it would haNTe—been very ill-advised for us to have made the "irrevocable and unambiguous" decision to convert our charter and withdraw our membership before we obtained charter approval from the Office of Financial Institutions, State of Louisiana. In our opinion, that certainly would have been "putting the cart before the horse". We have subsequently been ordered to maintain reserves on deposit with the Federal Reserve Bank of Dallas, beginning August 28, 1980. We have no alternative but to maintain these reserves, regardless of the effect on our bank, unless we can obtain an exemption. Therefore, we are writing you again to make our position very clear and to call on you for assistance. We sincerely feel that the fears and concerns expressed by several members of the House and Senate, when this legislation was pending have come to full fruition. We refer you to the Congressional Record, of the House dated March 27, 1980, when Mr. Hammerschmidt said: https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis "H-2289 Mr. Speaker, I am still somewhat troubled over a particular section of this legislation which would adversely impact on some banks in the congressional district that I represent. * * * * My primary objection is that the numerous banks across the Nation who have withdrawn from the Federal Reserve System will be penalized by this provision for action they have taken over 6 months ago. It would certainly seem more logical and equitable to modify the July 1, 1979, effective date to the date of the enactment of this legislation and to have the longer, 8-year phase in period for nonmembers applicable to these banks which have withdrawn to date. * * I would hopthis legislation would provide the Board of Governors some leeway in accomplishing the desired purpose of H.R. 4986 without forcing a "fire sale' and endangering these institutions. Is that the understanding of the gentleman of Board's discretionary * * * *" * * • Honorable Russell B. 4111, -3 September 16, 1980 After the foregoing concerns were expressed, Mr. Stanton the floor manager in the House for the bill states: "It certainly was the intention of the conferees and the frame rs of this legislation to allow just as the gefilleman has described, the Federal Reserve Board to have the discretionary powers to reco9nize that there are some hardships. in individual cases so that it could solve theseon an individual basis. * * * * It has been brought to my attention, as the gentleman says by the gentl eman from Michigan and the gentleman from Washington that there are certain individual banks in the country which were caught in a bind with regard to the grandfather date for withdrawing from the Feder al Reserve System. I am very pleased to 22-int up the congressional intent that indeed such flexibility will be given to the Federal Reserve Board in these particular cases. * * * *" As you will recall, on 5-3174, similar assurance was given by Senator Proxmire when Senator Bayh questioned him, relative to the provision of the act, and pointed out that there would be a "small number of financial institutions which would be unduly penalized, if restrictiv e interpretations were applied to this language". Senator Proxmire replied: "The Congress and the conferees did take into account the chance that there might be certain circumstances where an immed iate change in the requirement would cause si nificant losse s. In such cases, the conferees provided that the Federal Reser ve Board should take into account such other matters as it deems necessary to ameliorate the adverse effect of this change in reser ve requirements.' In view of the repeated assurances, given to the Congr ess, it certainly would appear to us that it would be fair and equit able that the Federal Reserve System take cognizance of our unique position, and of the unfair and unprecedented position which the legislation has forced upon us. We feel that this one paragraph provision in the law is very discriminatory and creates an EX POST FACTOsituation whereby we are sever ely penalized for our action taken prior to the passage of the law. We had completed our charter conversion and our Fed withdrawal on February 1, 1980, two (2) months prior to passage, The effect of this provision on our bank will be devastating insofar as our earninTand capital retention are concerned. We are at present a $36 million dollar bank, and we estimate the loss in earni ngs to our bank, if we do not grow at all, to be approximately $80,000.00 per year. This, in our opinion, is most unfair to our shareholders and to the cumunity which we serve. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis .. • Honorable Russell B. lIkg 4- September 16, 1980 One of the most frustrating aspects of our situation is that we have no practical method to combat this situation efficiently or effectively. If we attempted legal means in our effort, the process would undoubtedly be very long and expensive. There is no organized body to assist us. We are the only bank in Louisiana in this situation, and one of only three or four banks In the Dallas Federal Reserve District. As far as we have been able to ascertain, there are approximately only forty (40) banks in the entire United States which are affected by this one paragraph provision of the law. We are not asking for any special treatment. We are strongly urging you to consider our situation and make any efforts which you can to amend this discriminatory law and to allow us and other banks in our situation equal protection and the ability to phase-in our reserves over the eight year period as provided in the law. In essence, we are requesting status of a state, non-member bank, which we were on February 1, 1980. We trust this information will enable you to assist us in our efforts. However, should you require any additional, we will furnish any data at our disposal. Senator Long, please be assured that any efforts you make in our behalf will be most appreciated by us and also by the other banks in our same situation. Yours very truly, 0--// airman Philip F. Stafford, WDC/PFS:mh Enclosure https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis esident *ARO OF GLIVERNORS •e, or TH f GOt•I • • • • t•.• . pr„, . .„ • FEDERAL REEVE SYSTEM WASHINGTON, es., - •• • • s* C. 20551 ADDR(.. arrICIAL TO THE CO‘filial•ONOILINCE OA.° &AL PLS% • • July 17, 1980 W.D. Cotton, Chairman Philip F. Stafford, President First Republic Bank P.O. Box 877 Rayville, Louisiana 71269 Dear Messrs. Cotton & Stafford: This is in response to your letter of June 17, 1980, request ing that First Republic Bank (formerly First National Bank of Rayville), Rayville, Louisiana ("Bank") be permitted to phase-in the new reserve requirements under the Monetary Control Act of 1980 (Title I of the Depository Institutions Deregulation and Monetary Control Act of 1980, P.L. 96-221). The Act provides that a bank that was a member of the Federal Reserve System on July 1, 1979, and withdrew between that time and March 30, 1980, is required to maintain reserves to the same extent as a member bank. Nonmember depository institutions, including banks that withdrew from membership before July 1, 1979, are entitled to an eight-year phase-in of reserve requirements under the Act. According to the Board's records, Bank converted to a State charter and withdrew from System membership on February 1, 1980. Therefore, under the Act, it would be required to maintain reserves to the same extent as a member bank. In recognition of the fact than an individual bank's withdrawal from the System may have been delayed by individual circumstances, the Board, consistent with the legislative history of the Monetary Control Act, has issued an interpretation (12 C.F.R. 204.120) providing that a former member bank may present evidence that it made an unambiguous, irrevocable decision to withdraw from membership before July 1, 1979, and thus is entitled to an eight-year phase-in of required reserves. The interpretation provides that a former national bank whose shareholders voted to convert to a State charter prior to July 1, 1979, and was not a member bank on March 31, 1980, may present the Board with clear, unambiguous documentation of such action. You state in your letter that Bank commenced conversion discussions with the Louisiana Commissioner of Financial Institutions on May 11, 1979, and applied to convert to a State charter on September 27, 1979. According to information provided by Mr. Stafford to Ms. Melanie Fein of the Board's Legal Division, in a telephone conversation on June 26, 1980, the Bank's board of directors did not vote to conver until Novembe t r 13, 1979, and the shareholders did not vote to approve the conversion until https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis p. • 111 .• • is -2- 411 January 15, 1980. The Board regards the votes of both the directors and shareholders as necessary elements of an irrevocable decision by a national bank to convert to a State charter. Under the National Bank Act (12 U.S.C. § 214a), these votes are required before a national bank can convert to a State charter. Since these votes were not taken before July 1, 1979, Bank is regarded as having withdrawn from Federal Reserve membership after that date. Thus, under the provisions of the Monetary Control Act, Bank will be required to maintain reserves to the same extent as a member bank beginning with the seven-day reserve maintenance period that commences August 28, 1980. In recognition that former member hanks may experience hardship by being subjected to Federal reserve requirements by the August 28 maintenance period, the Board will consider granting limited extensions beyond that date in extraordinary circumstances. If bank desires consideration under this provision, please submit any relevant information to the Board before July 31, 1980. I have enclosed a copy of the Board's interpretation concerning the new Federal reserve requirements for your information. As Mr. Stafford requested in a telephone conversation with Ms. Fein on July 11, also enclosed is a list of former member banks that withdrew from System membership after July 1, 1979. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Depu y Secre ar ••• a •o d of t e Board https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis I3DAUD DI 11, I tilVF_PHDP r--) III( FEDERAL RESERVE SYSTEM dr)t,,.1 • .• . 4,11 RI • • • .. • • October 28, 1980 Thc . Honorable Lloyd Be ntsen United States Senator 9.1.2 Federal Building Austin, Texas 78701 near Senator Bentsen: Chairman Volcker has 'ask ed me to acknowledge re of your letter of Octobe ceipt r 24 requesting commen t on you received from Nr. Ga correspondence ry Woodburn concerni ng th e First National Bank, of Bellaire, Texa s. By statute, the Board' s primary supervisory is limited to State jurisdiction banks which are member s of the Federal Reserve System. Although all national banks are me mb er s of the Federal Reserve System, primar y supervisory author it y rests with the Comptroller of the Cu rrency. Therefore, I ha ve referred your .request to that agency for reply. .Sincerely, (Signed) Donald 5. Winn Donald J. Winn Special Assistant to the Board CC: Congressional Liaison Office Office of the Comptroller of the Currency CO:vcd (#V-404) bcc: Mrs. Mallardi /A LLOYD BEN TSEN 11- 'CAS https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Curre . ncy Inco 'ng will be referred to the Comptroller of the CommiTTFEF MANCE Liaison Office by the Co INN/MONMENT AND PUT31 IC WnPV.6; • JOINT ECONOMIC ?Jrnifc6 Zto fez. Zenale WASHINGTON. 0 C 20310 October 24, 1980 4 /1 • r I, if L Chairman Federal Reserve System Constitution Avenue bewteen 20th and 21st Streets, N.W. Washington, D.C. 20551 Dear Chairman: and I I recently received the enclosed constituent inquiry, any would very much appreciate your providing me with matter. pertinent information you might have regarding the Your kind assistance is greatly appreciated. cerely, ntsen Enclosure PLEASE REPLY TO: 912 Federal Buildina Austin, Texas 78701 ATTN: Mario Ortiz S Octobor 13, 1980 Senator Lloyd Bentsen Russell Senate Office Building 20510 Washington, D.C. Dear Sir: Regional We would appreciate your assistance in getting the against the Administrator of National Banks to take action First National Bank. property This bank is trying to "bulldoze" over the rights of g our deed owners in Richmond Plaza Subdivision by violatin rs, the bank restrictions. Despite protests by property owne commercial continues to use two lots in Richmond Plaza for purposes. have We the property owners do not want the deterioration we restriction seen in other neighborhoods as a result o1 deed We do not want a "shade tree" auto repair shop violations. used car lot with cars all over the front lawn, topless bar, or in Richmond Plaza. Plaza other There is currently no commercial activity in Richmond ing lot. The than the bank's attempt to build a commercial park bank's address is: First National Bank 5315 Bellaire Blvd. P.O. Pox 40 Bellaire, Texas 77401 Your assistance is appreciated. Sinefely, • / c \ ) ,,//7 ;_ A,?. ---_, , Gary Woo8burn Richmond Plaza Civic Association cc: file https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • 1 Octol:er 1980 l Panks Admillitrator of ;:ationa tr:'(t, ;1_1ite 3800 1201 75270 Dallas, Texas al charter of First Nation g in nk ba e th g in lk vo Pe He: 147860, Banl: Dear Sir: tional arter for the First Na ch nk ba e th lk vo re se ea s is: Would you pl t? The bank's addres us tr ic bl pu e th of n io Bank for violat First National Bank 5315 Bellaire Blvd. P.O. Pox 40 1 Prllaire, T(,x,1!: 7740 follows. r beina revolked is as te ar ch 's nk ba is th ton The reason for aza Subdivision in Hous Pl nd mo ch Ri of rs ne . The We the homeow sidential neighborhood re ul ef ac pe a in s me violating bought our ho g our neighborhood by in en at re th is nk Ba First National our deed restrictions. ty from small "pigpen" er op pr r ou t ec ot pr ns tree" Our deed restrictio homes such as "shade e th in d he is bl ta es g type businesses bein rked all over the front pa es cl hi ve th wi s r auto repair (1.3r1c.:e n we have seen in othe io at or ri te de e th nt wa We do not ated. lawns. strictions being viol re ed de e th of lt su neicihborhoods as a re across the street from od ho or hb ig ne e on in t A topless bar was buil has a used car lot in n io is iv bd su nt ce ja An ad a l'aptist church. her home. operating out of anot sh wa r ca a d an wn la one front • First National Bank th; , rs ne ow ty er op pr Plaza by Despite protests by the strictions of Pichmond re ed de e th e at ol vi continues to Instead of nk parking lot. ha al ci er mm co a as ts ral usinr two lo the 1-:,]nk has hi rd seve n, io at ol vi is th g discontinuin operty owners by some pr e th '' ze do ll bu '' s to "Philadelphia" lawyer to feel the hank's em se rs ce fi of 's nk The ba local technicality. ne from the law. money makes them immu f--; charter or, we want the bank' vi ha be s es kl ec wr 's nk of any Pun to this ba please scud us a copy u yo d ul Co u. yo Th,ink rcr:olked. to this case? correspondence relating https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Sifferely, 1_ atX Gary Woodburn sociation Richmond Plaza Civic As cc: cc: cc: cc: Congressman Bill Archer Senator John Tower Senator Lloyd Bentsen file Removal Notice The item(s) identified below have been removed in accordance with FRASER's policy on handling sensitive information in digitization projects due to copyright protections. Citation Information Document Type: Newspaper articles Citations: Number of Pages Removed: 3 "Letters." Suburbia Reporter. Pedersen, Nedland. "FNB Patrons' Use of Vacant Lot May Lead to Court Battle." Suburbia Reporter. Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Octoker 2S, 198C The honorable Howard H. Baker, Jr. United States Senate Washin9ton 4 D.C. 20510 Dear fenator Ltker Chairman Volcker has asked mc to ae.nc.:71edge your letter of OctoLer 27 requestiny our views on a letter you received from nr. T.I. Smartt. Va. Smartt expresses concern regardin,3 the activities of Citibank, N.A., New York, New York, in promoting a service called Citi-Shopuer. Citi-Shoprer is a merchandising service offered to holders of Citibankcredit cards by Comr-U-Card, Inc., an organization unrelated to Citibank. Citank is a national banl- and as such is under t!'.e jurisdiction of the Comptroller of the Currency. Citillank'r 1:arcnt coryoration, Citicorw, hew York, New York, is a Lan) holdinc company and its primary supervisory authority is the Federal Peserve Board. Eembers of the Board's staff contacted representatives of Citicorp rerdin,j the Citi-Shouper irogram and were advised that .,Tomotional activities questioned ty Mr. Snartt are performed the . by Citibank rather than Citicorp. We have, therefore, referred your request to the Cotroller of the Currency for nisporce. Sincerely, T1:::nald J. Winn r-ccial Lzsintant to the Board Congressional Liaicon Office of the Comptroller cf the Currency CO:rjt (#V-407) Lcc: Mrs. ',allardi%/e 1.:cc: https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis HOWARD H. BAKER, JR. TEN N ES SEE https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Zeitate STC-niteb WASHINGTON, D.C. 20310 tarrr • October 27, 1980 rnmmr Mr. Paul A. Volcker Chairman Federal Reserve System 20th and Constitution Avenue, N.W. Washington, D.C. 20551 Dear Mr. Chairman: I have enclosed correspondence from Mr. T. R. Smartt, which I believe is self-explanatory. I am grateful for your review of this matter, and for any information you might provide that will assist me in responding to this inquiry. Please respond to the attention of my staff assistant, Ms. Lee Hunt. Sincer ward H. Baker, HHBJr:rdt Enclosure r. 14 • • Sig.1Road . Chattanooga, Tenn 37405 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Tolephone: (615) 266 - 3157 Or,^ 2:52 801• September P, 19R0 4 Senator Howard Baker Senate Office Building Washington, DC Dear Senator Baker: It has recently been announced by Citibank, one of the nation's largest banks, that they are starting a new bankin service called "Citishopper". Tt is a telephone buying service, offered in conjunction with Comp-U-Card, Inc., of Stamfo/T1, Conneciicut; wIlich offers Citibank holders of their VISA and MasterCard, this buying service. The cost is based on $18.00 per year membership and it entitles the member the rigbt to purchase most small and major appliances among those items listed, at NO% off the manufacturers' retail price. This banking service offered to the customers of Citibank for marketing the Visa and MasterCard service is certainly a non-related banking service and must violate the charter of the Citibank. At best, this service does:et up an unfair competitive practice for the distributors and retail dealers of these products. Customers of these buying services are at a disadvantage insofar as delivered, damaged merchandise is concerned and service to these products when it is required. I would hope that this type of unquestionable banking service would cause you some concern and that we can look forward to your support in ending these practices. Fl HOWARD H. BAKER, JR. TENNESSEE -31Crti1eb Ziales -.Senate WASHINGTON. D.C. 20510 October 27, 1980 Mr. T. R. Smartt Smartt Cabinets 801 Signal Mountain Road Chattanooga, Tennessee 37405 Dear Mr. Smartt: MOomai. 4141-1,0c/1.: Thank you for your letter of September 2, 1980. I certainly appreciate hearing from you and hope you will forgive my extremely long delay in replying. r“ I understand your concerns regarding the growing number of "services" available through financial institutions which appear to fall outside the realm of acceptable or traditional "banking services". I am interested in receiving the reaction of the Federal Reserve Board to services such as the Citishopper plan you referenced, and I have requested the position of the Board for this purpose. I believe their assessment will be most informative for us both, and I will be pleased to advise you as soon as I receive a response. I do appreciate your bringing this matter to my attention and, again, I apologize for the delay in responding. I appreciate your interest and will be back in touch in the near future. ? Sincerely, OriOnal sip,ned by Howard Baker Howard H. Baker, Jr. HHBJr:rdt bcc: Chairman Paul A. Volcker '411111Pum."— https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Of 0-11. • 'No yA4 .1% .4 • • •r fi-,. ft ••••• • • 6• ( • -- • 1..4s :. ft? • .• •• OE GOvt •. 0 R • • i t C41 1/- BOARD OF GOVERNORS OF THE • • FEDERAL RESERVE SYSTEM •o • WASHINGTON, 0. C. 20 551 ••••• .RAL RE • • •..• • PAUL A VOLCKER r;iniPMAN October 31, 1980 The Honorable S. William Green House of Representatives Washington, D. C. 20515 Dear Mr. Green: Thank you for your letter of October 20 requesti ng my comments on two articles sent to you by one of your constituents. One article suggests that inflation is caused by increases in the Federal Reserve's discount rate. The other article evinces concern over the instability in interest rates--and in the monetary aggregates--that is perceived to have arisen from the operating policies adopted in October 1979. High interest rates commonly are associated with high inflation rates, but it is high inflation rate s that inevitably cause high interest rates rather than the other way around. In a period of rapid inflation, lenders insist upon interest rates high enough to compensate them for the anticipated decline in the purchasing power of the dollars they are lending. Borrowers are willing to pay these high rates because they too anticipate that both interest and principal will be repaid in cheaper dollars Higher interest rates tend to foster savings at the expense of consumption and to encourage the deferral of less promising investment projects--developments that reduce overall demands and reduce inflationary pressures. Since the discount rate is kept in reasonable alignment with the level of market interest rates, it also will tend to be high in times of rapid infl ation. We believe that it is premature to conclude that the operating policies adopted last October have been a failure, as suggested by the article from the Guardian. This year's environment has not been conducive to stable interest rate s nor to steady growth in the monetary aggregates. Monthly and quarterly movements in the growth of the monetary aggregates this year were substantially influenced by the sharpest economic contraction on record earlier in the year, followed by a very rapid recovery to positive economic growth. Moreover, policy was carried out https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • The Honorable S. William Green Page Two against a background of a series of changes in the federal budgetary picture, the imposition and subsequent removal of credit controls, the Soviet invasion of Afghanistan, and the outbreak of war between Iran and Iraq, all of which have left thei r mark on financial markets. In light of all these difficulties, the rele vant question with respect to this past year's policies is whether or not there were better ones available. Needless to say, the benefit of hindsight might suggest some alterations in poli cy; nevertheless, it should be noted that despite this year's prob lems, the monetary aggregates stand in reasonable alignment with the ranges set for this year. In addition, the Federal Reserve' s visible commitment to monetary restraint seems to have helped cont ain inflationary expectations. I hope that these comments have been helpful. let me know if I can be of further assi stance. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Sincerely, ,(A_ei/ecu/6 40-rapid. Please • jS. WILLI AM GREEN 1 titI4 DISTRt T. NI" W YIORK A1 .26iction assigned Mr. Kichline COIMMITTETS WASHINGTON OPFICE• 1 18 LONGWORTTE HOUSE OFFICE OUILDING WASHINGTON ID C. 20515 (202) 225-2436 FlANKINri. FINANC.0 AND URBAN AFFAIRS Congrts.5 of the linittb *tatc5 suscommirrrrs tinusiNc. R•40 cckgrotiNITY DE VELOPMENT GT T. N ONom IC • YAWL IZATION AL OVE R!•,-.14 I AND RE aGOT IA rioN ou5e of leprt5entatib0 ZZIasfiington, D.C. 20313 SELECT COMMIT 1(EON AGING https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis October 20, 1980 (212) 826-4466 229 FIRST AVENUE (14TH STREET) NEW Yor4K. NEW YORK 10003 (al 2) 826-4466 The Honorable Paul Volcker, Chairman Board of Governors of the Federal Reserve System Federal Reserve Building Washington, D.C. 20551 Dear Chairman Volcker: Enclosed are too articles from a constituent of mine. I would appreciate your comments on the major points on monetary policy. Best wishes. Si NEW VOIRK orricrs• 1628 SrcoNo AVENUE'(8 ITTI STREET) NEW YORK. Nrw YORK 10028 erel , • ( Bill Green Member of Congress BG:nwh Enclosures THIS STATIONERY PRINTED ON PAPER MADE WITH RECYCLED FIBERS Removal Notice The item(s) identified below have been removed in accordance with FRASER's policy on handling sensitive information in digitization projects due to copyright protections. Citation Information Document Type: Newspaper articles Citations: Number of Pages Removed: 2 Lewis, Ardron D. "Economy: 'Chains of Causation of Our Distress.'" New York Times, June 27, 1978. "Wall Street Echoes UK Disenchantment With Monetarism." The Guardian, September 28, 1980. Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org •• of GOvt •. R • .•••4-9 •ct, .c:4, • -,, , ROARD OF GOVEPW7PS Cc THE , • ., FEDERAL RE5ERVE SYSTEM WASHINGTON, D. C. 20551 Lfirjr. • 14;4'4 ( c,-:•/ 1 4" •" •• i?, 11. Ri.S ••• • • •.. • • • PAUL A. VOLCKER CHAIRMAN October 31, 1980 The Honorable Bruce F. Vento House of Representatives Washington, D. C. 20515 Dear Mr. Vento: Thank you for your recent letter regarding the Federal Reserve's interest rate policies. I can assure you that it is not the objective of the Board or of the Federal Open Market Committee to bring about high or widely fluctuating interest rates. The insta bility of money and interest rates this year has certainly been a matter of concern to me, as it has been to you. Inflation is too high, productivity remains low, and we have too many unemployed. But the only relevant question is whether these conditions would have been better or worse with a different monetary policy, and I feel reasonably satisfied about the technical changes introduced last October. I'm sure you can appreciate that the circumstances in which the Federal Reserve has operated in the past year have been extraordinary. We've seen tremendous variations in the rate of increase in major price indexes and in the intensity of inflatio nary expectations. The federal budgetary picture has gone throu gh a series of significant changes. We've experienced the shar pest economic downturn of the postwar period, but it also appears to have been extraordinarily short and unemployment has remained well below levels projected some months ago. Credit controls were instituted and subsequently removed. The Soviet invas ion of Afghanistan and the Iran-Iraq war have given rise to serious conc erns that have left their mark on financial markets. This has not been the sort of environment in which one could reasonably expe ct stability in interest rates and steady monetary expansion. This is not to say that, as always with the benefit of hindsight, I might not have chosen to modify somewhat the course of policy this year. But even so, I think that our performa nce has had a significant measure of success. In assessing our record with respect to monetary control, I would argue that it is not the month-to-month or quar ter-toquarter movements in the money supply that matter, but rather the longer trends. In that regard, it may be noted that, despite the difficult circumstances in which we have operated, the monetary https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • The Honorable Bruce F. Vento Page Two aggregates at this point stand in reasonable alignment -although a bit higher than we would like -- with the ranges we set for the year. Moreover, I firmly believe that our visible commitment to a policy of monetary restraint has helped to contain inflationary expectations in the face of some extremely troubling developments that would have otherwise led to substantially higher inflation. Our determination to avoid excessive monetary expansion has, to be sure, played a role in the recent increase in interest rates. However, it must be said that such factors as the talk of a deficit-expanding tax cut, the impetus to inflation from recent agricultural adversities, and the fears of economic dislocation in connection with the turmoil in the Middle East-as well as the surprising strength of the third quarter economic rebound and the lack of progress in moderating underlying wage/ price trends--have contributed importantly to the very negative psychology prevailing in the debt markets. But while the rise in interest rates cannot be regarded as a favorable development at this early stage of an economic recovery, I don't think that a shift in System policy toward greater monetary accommodation would have proven wise. Quite likely the result would have been a still more pronounced aggravation of inflationary expectations, with negative implications for interest rates and future economic stability. In a meaningful sense, we have been following the steadier course by permitting interest rates to rise as monetary expansion accelerated in the past few months. The rise in rates does tend to focus attention on those segments of the economy that may be relatively hard hit by a tightening of credit conditions. However, I must say that our experience with the credit control program earlier this year has made me more certain than ever that government-directed credit allocation schemes should not be a standard feature of our financial landscape. The Federal Reserve, as you know, has no significant allocative powers at present, and it probably is best that it remain so. Credit controls are extremely difficult to manage in a way that is equitable and that avoids undesirable distortions of funds flows. Jawboning and other informal techniques must for the same reasons be used with care--and are unlikely to be effective for extended periods in the face of contrary market pressures. By and large, our highly competitive financial system can be expected to bring about a more efficient allocation of credit among the many potential borrowers in our economy than any governmental agency. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 0 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The Honorable Bruce F. Vento Page Three 1 think that the only real hope for attaining on a sustained basis lower, more stable nominal interest rates and an environment conducive to productivity-enhancing capital formation lies in a return to greater price stability, which in turn is dependent in part on the persistent application of reasonable monetary and fiscal restraint. We recognize that what the Federal Reserve does has significant consequences for the economic fortunes of our nation, and within that basic framework, the Federal Reserve will continue to subject its policies and procedures to the most intense scrutiny to ensure that its actions are as effective as possible in serving the public interest. Sincerely, / 2 C(1)4' 6A4 Paul A. Volcker Action assigned Mr. Richline - E3RUCE F. VENTO 41DIS1RCT, MINNESOTA • • HOUSE COMMITTEE ON BANKING. FINANCE AND URBAN AFFAIRS 230 CANNON V.ICKP3E OFFICE BUILDING SUBCOMMITTEES- (202) 225-6631 ECONOMIC STABILIZATION Congrr5.5 of the V.Iiiitcb tate5 DiSiRicTOFFICE, 31)oti5e of iktpressentatitn ROOM 150 Mtmas PARK PLACE 405 SIBLEN, STREET SAINT PAUL MINNI OTA Ulasijington, D.C. 20315 55101 OW 225-7724 October 7, 1980 CONSUMER AFFAIRS HOUSING AND COMMUNITY DEVELOPMENT HOUSE COMMITTEE ON INTERIOR AND INSULAR AFFAIRS SUBCOMMITTEES ENERGY AND THE ENVIRONMENT NATIONAL PARKS AND INSULAR AFFAIRS Mr. Paul A. Volcker, Chairman Federal Reserve Board Federal Reserve Building Constitution Avenue Washington, D. C. 20551 Re: High Interest Rates Dear Chairman Volcker: I am writing to express my strong opposition to the Fed's recent decisior6 to raise the discount rate in order to control recent growth in the money supply. This action has effectively forced the nation's banks to raise their prime interest rates to the unreasonably high interest levels of 13.5% and 14% and, in my opinion, will likely precipitate negative economic consequences. One year ago today, the Fed unveiled its new policy of targetting growth in the monetary aggregates while allowing interest rates to fluctuate with the market. The Fed adopted this policy in the hopes that it would prove more effective than past interest rate pegging policies at promoting moderate and steady monetary growth. Unfortunately, this new Fed policy has not proven successful. In fact, in the past year, this country has experienced highly erratic monetary growth together with the widest swings in interest rates that we have ever known. As a result of these broad interest rate swings, long term capital markets have been brought to the brink of disaster through a lack of investor confidence. Unless the Fed begins to re-examine the miserable performance of the economy under its heavy-handed ways and becomes more sensitive to the effects of fluctuating interest rates, I think the current economic pattern of long term investment instability, short term capital outflows and an insecure dollar will continue to persist and eventually pose a serious threat to our entire savings and investment structure. In the House Banking Committee's August 19th rebuttal to your bi-annual monetary policy report, we strongly urged the Federal Reserve to pursue a policy of measured restraint so as to control inflation and excessive monetary growth without precipitating a downturn. This country needs a stable and consistent monetary policy that will allocate scarce credit to productive concerns and give investors the confidence to make important long term investments. Merely tightening the reins across the board flies in the face of the depressed industries, small businesses and thousands of unemployed workers who are finally feeling some economic hope after two of the worst quarters in recent years. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis THIS STATIONERY PRINTED ON PAPER MADE WITH RECYCLED FIBERS • Mr. Paul A. Volcker October 7, 1980 Page Two During the past year, the Fed has shown itself quick to clamp down when the economy becomes heated, but unrelentingly slow at providing relief when a stimulus is needed. The recovery which the economy now appears to be in is an encouraging sign that should not be stamped out through heavy handed restraint. In this case, the Fed should exercise judicious encouragement of the recovery by implementing an extensive microeconomic program to curb banks from making speculative loans for purely financial activities such as stock buy backs, corporate takeovers and foreign exchange purchases and instead pressure banks to channel credit into areas in need of production-enhancing capital such as housing, agriculture and small business. The Fed has the tools to implement such a program and it certainly should use them. If the Fed continues on its current course of extreme restraint, I fear that it will only destroy the progress our economy has made in recent months and likely lead to a recessionary relapse accompanied by higher federal deficits, increased instability in our savings and investment structure, and further unemployment and domestic social upheaval. Again, Mr. Chairman, I strongly object to the Fed's continued use of high interest rate policies and strongly urge you to make a careful re-examination of the effects your actions have had. Thank you very much. Warm regards. Sit 621ely,— . Vento Member of Congress BFV:mc https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis