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BEFORE THE FEDERAL RESERVE BOARD AT WASHINGTON. In the Matter of the PETITION TO TRANSFER A FOR- TION OP SOUTHERN OKLAHOMA FROM FEDERAL RESERVE DISTRICT NUMBER ELEVEN TO FEDERAL RESERVE DISTRICT NUMBER TEN. ANSWER AND BRIEF OF R E S P O N D E N T THE F E D E R A L R E S E R V E BANK OF DALLAS. CHARLES C. HUPP, CoimseL W . M. W arllolc. L aw P ., 810% M ain S t., D allas. V hone M. <0»1. CO NTENTS Pages Special Exceptions to P etition................................ 2-4 Formal Answer of Respondent ................................ 4-7 Remarks .................................................................... Counter Propositions (a), (b), (e), (d), and (e ).. 11-12 Statement under Counter Propositions (a), (b), (c), (d) and (e) ...............................................12-17 Counter Propositions (a), (b), (c), (d), (e), (£), and (g) .............................................................. 17-19 Statement under Counter Propositions (a), (b), (c), (d), (e), (f) and (g) ......................................... 19-28 Argument under Counter Propositions Submitted by Respondent and in Reply to Contentions made in Petitioners’ Brief ................................ 28-56 Appendix ......................... ....................................... 57-101 Exhibit A, 1 to 22, inclusive.............................. 59-73 Exhibit B, 1 to 2 ................................................ 73-74 Exhibit C, 1 to 14, inclusive.............................. 74-81 Exhibit D ............................................................ ^2 Exhibit E ........................................... 82-83 Exhibit P, 1 to 26, inclusive..............................84-97 Exhibit 6 ......................................... Q7 m i BEFORE THE FEDERAL RESERVE BOARD AT WASHINGTON. In the M atter of the PETITION TO TRANSFER A POR TION OF SOUTHERN OKLAHOMA FROM FED• ERAL RESERVE DISTRICT NUMBER ELEVEN TO FEDERAL RESERVE DISTRICT NUMBER TEN. ANSWER AND BRIEF OF R ESPO N D EN T THE FEDERAL R ESE R V E BANK OF DALLAS. To the Honorable Federal Reserve B oard: The petition filed herein seems to be a joint petition and brief, and does not appear to be in conformity with the regulations of the Federal Reserve Board with reference to petition and supporting brief. In reply ing thereto, this Bank, which will be referred to herein as respondent, will, therefore, file its answer to the pe tition, and in support of its answer, follow with its brief answering the petition of the Committee and supporting the answer so made by it. Now comes The Federal Reserve Bank, of Dallas, Texas, respondent, and, answering the petition filed with your Honorable Body, purporting to be 011 behalf of “ Certain Banks in Southern Oklahoma" and asking the Board to change the lines of F e d e ra l R eserve D is trict No. 10 and F ederal R eserve D is tric t No. 11, so th a t all of Oklahoma except th e C ounties of M arshall, B ry a n , Choctaw, P ushm ataha and M eC urtain w ill be in D is tric t No. 10, says: I R espondent specially excepts to th e p e titio n so filed by three parties, to-wit, F ra n k C raig, P re s id e n t o f th e City N ational B ank, of M cA lester, O k lah o m a; G uy C. Robertson, C ashier of th e F ir s t N a tio n al B an k , of L a w ton, Oklahoma, and W . B. H a rriso n , S e c re ta ry of th e Oklahoma B an k ers’ A ssociation, of O k lah o m a C ity , Oklahoma, p u rp o rtin g to ac t as a com m ittee fo r c e rta in banks in S outhern O klahom a, fo r th e fo llo w in g reaso n s, v iz.: (a) The said p etitio n is n o t e x e cu ted in th e m a n n e r and form prescribed by said F e d e ra l R eserv e B o ard , governing the procedure in ap p eals fro m th e decisio n of the R eserve B ank O rg a n izatio n C om m ittee, in t h a t the same is not signed b y tw o -th ird s of a ll th e m em b er banks in th e te rrito ry so u g h t to be tr a n s f e r r e d , b u t is in fact signed by th re e in d iv id u a ls, a c tin g in th e ir in d i vidual capacity as a com m ittee. (b) The m em orandum a p p e a rin g o n th e fin al p a g e of said petition, p u rp o rtin g to b e a co p y o f a p e ti tion alleged to have been sig n ed b y c e rta in b a n k s in S outhern O klahom a, is n o t a f a ir o r tr u e r e p r e s e n ta tion of w h a t is in fa ct, on file w ith sa id F e d e r a l R eserv e B oard, b u t sam e is an a tte m p te d c o n so lid a tio n b y sa id committee, of c e rta in slips o r m e m o ra n d a o f p r o te s t claim ed by said com m ittee to h a v e b e e n e x e c u te d by ce rtain b anks im m ediately fo llo w in g th e a n n o u n c e m e n t 3 of the district lines by the Federal Reserve Organization Committee, which action, if any, upon the part of said banks, was long prior to the filing of the petition herein by said committee, and it nowhere appears in said pe tition that said banks, for which this committee claims to be acting, filed this petition for transfer or authorized their names to be used in connection therewith, or author ized this committee to refer to any previous action taken by them as a basis of seeking to show that they were joining in this contest. (c) At the time the petition signed by Frank Craig, of McAlester, Oklahoma; Guy C. Robertson, of Lawton, Oklahoma, and W. B. Harrison, of Oklahoma City, Oklahoma, was filed by them, it does not appear th at a majority of the banks listed by them as peti tioners had knowledge that their names were being used as petitioning banks asking for a transfer, or that said banks were informed or had knowledge that any prior protest or action upon their part was being used, and urged as a basis upon which to insist, that they were petitioning a transfer from the Eleventh District to the Tenth District. (d) That the petition so filed, which this respond ent is called upon to answer, is replete with references to letters, statements and data, which said committee filing said petition state are being filed with said peti tion, and called to the attention of the Federal Reserve Board, and this respondent here says that so much of said petition as refers to said letters, statements and data mentioned in said petition, should be stricken out, and that said letters, statements and data mentioned in said petition should be stricken from the record herein. 4 for the reason that said petition and the additional tes timony referred to therein, to-w it: the letters, state ments and data, constitute new testimony introduced on this hearing for the first time and not adduced before the Organization Committee, and, therefore, cannot be considered under the regulations of this Board governing appeals from the decision of the Reserve Bank Organiza tion Committee. II For further answer to said petition and in support of the exceptions set out in paragraph one above, this respondent says that the petition filed by said committee did not, at the time of its filing, and does not now, cor. rectly represent the real wishes and sentim ents of the officers of a large number of the member banks listed in said petition on the final page thereof as petitioning banks, many of whom, subsequent to the filing of said memoranda of protest with the Reserve Board, imme diately after the announcement of the district lines by the Federal Reserve Organization Committee and pre vious to and subsequent to the filing of said committee's petition, after they had taken time to thoroughly con sider the Organization Committee’s action and their own best interests, have expressed themselves both in w rit ing and verbally, to the effect th at they are satified with the lines established, and that no action should be taken at this time looking to a transfer of any portion of the territory from the Eleventh D istrict to the Tenth Dis trict, and this respondent believes, and upon such infor mation and belief alleges, that resort was made by said committee to said claimed memoranda of protest for a compliance with the rules established by this Board, 5 requiring the signature of two-thirds of the member banks in the territory sought to be transferred only, because said committee feared that they could not, at that time, have secured the necessary signatures of twothirds of the member banks in the territory sought to be transferred, as required by the regulations of this Board in this character of proceeding. In support of the allegations in this paragraph con tained, and as illustrative of our position on the excep tions contained in paragraph one above, reference is here made to copies of letters from officers of certain mem ber banks listed in said purported petition as petition ing banks found in the appendix to this brief and marked Exhibit A, numbered 1 to 22 inclusive, to which letters the considerate attention of the Board is re quested. I ll For further special answer herein, respondent states th at it is well known that, at the time the protest slips were signed by some of the member banks, many of the banks executing them were influenced in so doing by an appeal to their State pride and were opposed to the action of the Organization Committee in the establish ment of the lines solely because the State of Oklahoma was being divided and the Northern portion of said State placed in the Tenth District and the Southern por tion of said State placed in the Eleventh District, and th at said committee filing the petition herein, has segre gated certain counties with a view of leaving them in the Eleventh District and that this Board cannot assume th at the lines fixed by the committee of three would meet the wishes of the member banks, if said banks were 6 executing the petition themselves, as they would be required to do under the rules of this board if they were in fact asking for a change of Federal Reserve D istrict lines. IV For further special answer, respondent says th a t the activity for a transfer of territory from the Eleventh District, to the Tenth District, arose outside of the te rri tory sought to be transferred, and th a t whatever action in the way of protest that was made by member banks within the territory sought by said petition to be tran s ferred was taken upon the invitation and request of parties residing outside of the territo ry sought by said petition to be transferred, and this respondent here sug gests that such outside action was inspired by a laudable ambition upon the part of certain parties non-resident of the territory sought to be transferred, to so arrange the district lines as that the thriving, prosperous and progressive city of Oklahoma City, Oklahoma, m ight stand a ehance to be considered favorably as a location for a branch bank of the Kansas City Reserve Bank. In support of the suggestion herein made, reference is here made to copies of two letters sent out from Okla homa City, Oklahoma, on April 7 and 13, respectively, found in the appendix and marked Exhibit B, numbered l a n d 2. V For further answer, respondent says th at there is no widespread dissatisfaction among the banks of Southern Oklahoma to the location of the present lines of the Tenth »ad Eleventh Districts, as would appear from the state ments in the petition filed herein, and as indicative of 7 this fact, reference is here made to copies of letters from banks in Southern Oklahoma, addressed to the Federal Reserve Board, and to officers and member banks of the Federal Reserve Bank of Dallas, copies of which letters are to be found in the Appendix, marked Exhibit O, numbered 1 to 14, inclusive. REMARKS. Regulation 1, by the Federal Reserve Board, govern ing procedure in appeals from the decision of the Fed eral Reserve Organization Committee, provides, among other things, as follows: “ Petition for review of the determination of Federal Reserve Districts by the Organization Com mittee must be signed by duly authorized officers of at least two-thirds of the member banks in the territory which the petition asks to be taken out of one district and annexed to another.” Is the petition herein in conformity with this regula tion? The parties who filed this petition do not claim th at the member banks for whose benefit it was supposed to be filed, ever saw it, signed it, or authorized any one else to sign it for them, or even had an opportunity to sign same. In order to show a semblance of compliance with the regulation of this Board, the committee so filing the petition refers to protest slips claimed to have been filed by certain banks in the territory sought to be transferred. There is no claim made that the member banks designated as petitioning banks authorized this committee to include them as petitioning banks on ac count of some prior protest. These protests, if made, were made before the organization of this respondent, and at a time when the protesting banks had no means of 8 determining w hether they could o b tain satisfa c to ry ser vice from the Dallas B ank or n o t, a n d such p ro tests as were made were made, n o t upon th e in itia tiv e o f m em ber banks, but in response to th e in v ita tio n of p a rtie s out side of the territo ry sought to be tra n s fe rre d . These p ro tests, when made, w ere m ade la rg e ly in response to State pride and were m ade la rg e ly because th e S tate of Oklahoma was being divided. A fter the Eleventh D istrict h a d elected as one of its Directors a m an from S o u th e rn O klahom a, w ho was familiar w ith the w ants a n d needs o f th a t te rrito ry , and after this respondent w as org an ized a n d began business, it nowhere appears th a t a n y m em ber b a n k in Southern Oklahoma p ro tested a t b ein g in clu d ed in th e Eleventh D istrict, or th a t an y n u m b er of m em ber banks in this territo ry then availed them selves o f th e oppor tunity afforded them by th is B oard, of filing a p etitio n to be transferred to th e T enth D istric t. We submit to this B oard t h a t th e re is no p etitio n prepared, signed an d filed b y tw o -th ird s o f th e m em ber banks in the te rrito ry sought b y th is p u rp o rte d p etitio n to be transferred from re sp o n d e n t’s d is tric t to the Tenth District, as re q u ired b y y o u r re g u latio n s, and that this question is fu n d a m e n tally ju risd ictio n a l, and that, therefore, this B oard should su sta in re s p o n d e n t’s exceptions contained in p a ra g ra p h one of its answ er an d th at this proceeding should h e re now b e dism issed. Regulation No. 1, p ro m u lg ated b y th is B o ard fo r guidance in proceedings o f th is c h a ra c te r, am ong o th er things, provides: “ The B oard w ill n o t h e a r testim o n y , b u t th e parties will be lim ited to th e re c o rd b efo re th e O r ganization C om m ittee.” 9 The purported petition filed herein nowhere refers to the record made before the Organization Committee, but said petition is based solely upon letters, statistics and testimony which the petitioning committee says it was filing with this Board at the same time it filed the pe tition. This respondent earnestly urges and insists that it should not be called upon to answer new m atter and testimony filed with the Board in support of the purported petition, and which this respondent has never seen and has no way of seeing, and which was not a p art of the record made by the Organization Committee, and respectfully insists that its special exception (d), found in paragraph one above, should be in all things sustained, and that said letters, statistics and data so referred to in said petition, constitute new testimony, not adduced before the Organization Committee and should not be heard or considered by this Board, and th at such new m atter and additional testimony should be purged from the record herein and that its exceptions should be sustained to such portions of the petition as are based upon or refer to such new and additional testimony. In connection with the exceptions in paragraph one above, the B oard’s consideration is also asked of the special answer of respondent, contained in paragraph two, and particularly to the letters therein referred to, copies of which can be found in the Appendix. Respondent has made no special effort to obtain an expression from the member banks listed in said petition as petitioning banks, but believing that a great number of said banks have not authorized the use of their names in connection with this proceeding and believing that a great number 10 of said banks so mentioned in this petition as petition ing banks were in fact satisfied and content to remain as member banks of this district, respondent asked an expression from a few of the banks best known to it, with the result that each bank so inquired of has an swered that it was making no effort to have territory taken from respondent’s district and placed in the Kansas City district, and that it was satisfied with the district lines as established by the Organization Commit tee, and that they did not feel like any effort should be made to change the lines of the district until a fair test had been given the action of the Organization Com mittee, the letters made use of herein being irrefutable proof of the contention of this respondent that the pur ported petition was not in fact the petition of the banks listed in said petition as petitioning banks. It is here respectfully suggested that the use of these letters by respondent cannot be considered as the intro duction of new testimony, but should necessarily be considered in support of its jurisdictional objection and as going to the good faith of the purported petition which it is here required to answer. R E P L Y TO T H E C O N T E N T IO N S M A D E IN THE P E T IT IO N AND B R IE F F IL E D B Y T H E C O M M IT T E E . If this Board should fail to sustain our contentions above, and should decide to consider the petition filed by the committee, then this respondent requests that it be permitted to further answer to the merits of said pe tition. 11 The petition states that the transfer of territory should be made: “ F irst—Because the present districting is not in accordance with the spirit of the law which pro vides, in Section 2, ‘the districts shall be appor tioned with due regard to the convenience and cus tomary course of business.’ ” In reply to the first contention of petitioners, the following propositions are respectfully subm itted: (a) In establishing the present district lines, due regard was given by the Organization Committee to the same question here presented by petitioners, and the present lines were established, because it was evident that the greatest volume of commerce from Southern Oklahoma was southward and to the Gulf. (b) The large volume of commerce from Southern Oklahoma being to the southward and through Texas, no violence was done in placing Southern Oklahoma in the Eleventh District, with its Bank at Dallas, Texas. (c) The principal crops and products of Southern Oklahoma being identical with Texas products and crops, the Dallas Bank can understand and care for the wants and necessities of Southern Oklahoma much better than the Kansas City Bank or any other Bank. (d) The Organization Committee having taken much time and painstaking care in the establishment of the present district lines, and it being apparent that it was an absolute impossibility for any committee to so district the United States as that its action would meet with the entire approval of all persons, both within and without each respective district, the action of said com mittee should be given full faith and credit, and no 12 change should be m ade in the presen t d istrict lines of the Tenth and Eleventh D istricts u n til a reasonable time lias passed and the action of th e Committee has been given a full and fa ir test, to the end th a t the Federal Board could then determ ine w hether or not any error had been made by the inclusion of any te rrito ry within a given district. (e) All of Southern Oklahom a being nearer Dallas than Kansas City, it was not only p ro p er b u t necessary that it be included in the E leventh D istrict, and the fact th a t possibly a m ajo rity of its banks had hereto fore done considerable business w ith K ansas City banks, furnishes no reason w hy the action of the Organization Committee should be overruled and th a t territory, sit uated almost at the door of the D allas Reserve Bank, should be tra n sfe rre d to a b ank situ ated hundreds of miles away. STATEMENT UNDER TH E ABOVE PROPOSITIONS. The petition, under subdivision headed “ Course of Business,” refers to d a ta which petitioners state was being filed w ith this B oard, and inasm uch as such data is not accessible to respondent, it will be impossible for it to reply fully to the new m atter and testimony which it has never seen and which it has no opportunity of seeing. In addition to the record of the Organization Com mittee, respondent, solely for the purpose of answering the new m atter and testim ony filed by petitioners, and without waiving its objection to a consideration by the Board of such new testim ony, also will use and refer to some additional letters and statem ents not found in the 13 record of the Organization Committee, copies of which will be found in the Appendix to this brief. Particular reference is here made to the maps found on pages 108, 109, 110 and 111 of the copy of the record filed by the Organization Committee with the Senate of the United States, the date of the letter transm itting such record being May 18, 1914. On page 115 of said Senate Record will be found the following: “ Signed statements from the Dallas jobbers show th at they sell to 28,280 merchants in Oklahoma, 3,151 merchants in New Mexico, 5,698 merchants in Arkansas and 7,222 merchants in Louisiana.” On page 116 the following: “ The map attached will show that all of the ter ritory claimed in Oklahoma, Arkansas and Louisiana, is within 15 hours by rail from Dallas. That every portion of the territory can be reached from Dallas in less time than from St. Louis. With the exception of a small portion of northern Oklahoma, north of the Cana dian River, it can be reached from Dallas b.v rail in shorter time than from Kansas City. The only portion of the territory that can be reached from Denver in a shorter time than from Dallas is the northern half of New Mexico, and a small portion of the Panhandle of Texas. Less than 5 per cent of the population in the te r ritory, exclusive of Texas, can be reached more quickly from Kansas City or St. Louis, than from Dallas. Eight hundred and ninety-three of the 943 National banks are nearer Dallas than they are Kansas City, St. Louis, Denver or New Orleans. One thousand, seven hundred and sixty-one of the 1,816 State banks are nearer Dallas than any other of the cities mentioned.” 14 On pages 317 and 118 the following: “ It is a region in every sense, express and implied, in which that word is used under the law. Including the relatively small territory outside of Texas, which has for its convenience been put with Texas, and which can with most advantage to it be best served from a Texas bank, the region contains or produces approximately: “ One-sixth of the area of the United States (such area is large enough for a district, while, if added to the other territory claimed by St. Louis, the enlarged district would embrace approximately one-third of the total area of the United States). “ One-twelfth of the population of the United States (the increase during the last decade being 39 per cent). “ One-eighth of the National banks of the United States. “ One-tenth of the State banks of the United States (the number of total banks increased in the last 14 years 454 per cent). “ One-seventh of the total farm production of the United States ($1,000,128,597). “ Two-fifths of cotton production of the United States ($381,132,400). “ Four-ninths of total cotton-seed production of the United States ($54,785,550). “ One-tenth of live-stock production ($205,224,132). “ One-half of cotton exports ($253,020,000). “ One-eighth of the total exports of the United States. “ With the exception of some territory in the extreme western and southern portions of the district, and a small area in southwestern Louisiana, every point in the dis trict is within 12 hours7 mail service of Dallas, and those remote portions of the territory are within closer • mail service to Texas cities than any other city which has been under consideration as a location for a regional bank.” 15 On page 118 the following: “ For eight months in every year a regional bank in this district would have money to loan; for 12 months in an ordinary year it could take care of its own member banks and have money left. During the exceptional year (1913) just passed, it could, at the peak of its advances to member banks, have financed itself. If, however, under extraordinary stress, it should need to re-discount the receivables of member banks to a small extent with other regional banks, or to issue emergency currency, it would simply be making use of these features of elas ticity which have been advertised as among the chief excellencies of the new banking law. “ If the Texas regional bank should be a lender bank 8 months out of every year, and 12 months out of an ordinary year, why should it not every 4 months, during an occasional extraordinary year, be a borrower or noteissuing b an k ?'’ William Mee, President of the Oklahoma City Clear inghouse Association, testifying before the Organization Committee at Kansas City, said that the Oklahoma banks did business largely with Kansas City banks, and then added: “ The cotton interests are divided to the East almost altogether, New York and Boston, very largely” (p. 1919, typewritten copy of Testimony taken by the Organization Committee). P. C. Bings, of the Guarantee State Bank of Ard more, Oklahoma, testified before the Organization Com mittee at Kansas City, that he was there as a committee representing the southern part of Oklahoma for the Oklahoma Bankers’ Association, and, while so testify ing, he was interrogated by the Secretary of the Treas ury, and answered as follows: 16 “ The Secretary of the Treasury: If you did not have it at Kansas City, where would you then prefer itf “ Mr. Bings: As I say, it does not make any differ* ence to me as long as we have a branch bank in our own State. “ The Secretary of Agriculture: You are pretty near Ft. Worth and Dallas. You do not want to be connected with a bank at any place in Texas? “ Mi*. Bings: I am afraid that neither F t. Worth nor Dallas will get a regional bank, hence we would have to go further south, to New Orleans. “ The Secretary of Agriculture: Suppose one were at Dallas? “ Mr. Bings: That would be our second choice. “ The Secretary of the Treasury: It would be? “ Mr. Bings: Yes, sir, from the fact that three months in the year there is the cotton season and 60 per cent of our business goes south of Ft. Worth, Dallas or Hons* ton” (pp. 1998 and 1999, Transcript of Testimony taken by the Organization Committee). Sam I. Hynds & Company, cotton merchants, and members of the New Orleans Cotton Exchange, in a le t ter to B. A. McKinney, a Director of respondent, made the statement that practically all of the cotton produced in Oklahoma, sold for export and to New England mills, passes through Texas ports or New Orleans, and, further, that farmers and merchants who ship cotton on consign* ment forward same to Houston, Galveston or New Or leans. In other words, almost the entire Oklahoma cot ton crop is shipped by way of the Gulf. See letter in Appendix, marked Exhibit D. Frank Kell, the principal owner of the W ichita Mill & Elevator Company, and the Oklahoma City Mill & Elevator Company, the largest mill operator and grain 17 dealer in the Southwest, in a letter to B. A. McKinney, a Director of this respondent, shows that practically 90% of the grain, such as wheat, oats and corn, raised in Southern Oklahoma, moves southward and is consumed in Texas and Louisiana or moves out through Texas Gulf ports. See letter marked Exhibit E in Appendix. Particular attention is called to the trend of ques tions asked by the Secretary of the Treasury at the hear ings in Kansas City and Austin, which indicates that the matters made the basis of this first complaint in the petition were being duly considered by the Organization Committee. The second proposition advanced by petitioners, headed ‘‘Loan and Discount Facilities, ” is as follows: “ Second—In the second place, Southern Okla homa should be placed in the Kansas City District, because the figures show the Kansas City District will be better able to meet the re-discount require ments of the Southern Oklahoma banks, than will the Dallas District.” In support of this proposition, petitioners use data and new testimony not contained in the record of the Organization Committee, a great part of which is not fully shown in the petition. In reply to the second contention so made by peti tioners, respondent respectfully submits counter-propo sitions as follows: (a) The reports of the Dallas Reserve Bank, made to this Board, and of which this Board is fully apprised, show conclusively that the petitioners’ fears are unfound ed and that the Dallas Reserve Bank is able to furnish 18 proper and adequate discount facilities to all of its member banks, including the banks in Southern Okla homa, and that the Southern Oklahoma banks have al ready begun to use the Dallas Reserve Bank as a medium of discount, and that of the discounts made by the Dal las Reserve Bank, 25% of the amount was for Southern Oklahoma banks. (b) The showing of petitioners under their second proposition proves only and conclusively that the banks in the Eleventh District in Texas and Louisiana are thoroughly cognizant of the needs of their territory, and furnish readily and fully the necessary funds with which to move the products and crops of their territory, and that, when necessary, they will borrow sufficient money for this purpose. (c) The Federal Reserve Act was purposely designed to take care of ,iust the contingency suspected by the petitioners to arise, but which has not been shown by the petitioners to have arisen; and if such a contingency should arise, adequate provision therefor is made in the Act without the necessity of changes in district lines. (d) The petitioners wholly fail to show any condi tion of inability upon the part of the Dallas Reserve Bank to properly care for the needs and necessities of the Southern Oklahoma banks, and until such a condition is shown, there can certainly be no reason or cause justify ing a reversal of the judgment of the Organization Com mittee in establishing the present district lines. (e) Neither the present district lines nor the terms of the Federal Reserve Act prevents any member bank in Southern Oklahoma from carrying an account with any other bank in Kansas City or elsewhere, and the in- 19 elusion of Southern Oklahoma in the Eleventh District does not deprive any member bank of its right or privi lege of carrying an account with Kansas City banks, if it desires. (f) According to the terms of the Federal Reserve Act, it is impossible for the reserve banks to reach their full measure of strength and usefulness for a period of three years from the date of the opening of the banks, and until such a length of time has elapsed in which to permit the reserve banks to in a measure reach the maximum of their strength and efficiency, certainly no action should be taken by this Board changing the pres ent lines of Districts Ten and Eleven, because at this time the banks have not been in operation a sufficient length of time to enable the Board to correctly determine whether the judgment of the Organization Committee in establish ing the present lines was erroneous. (g) The very purpose of the Federal Reserve Act was to furnish stability to our financial system and to change some former methods in the banking world, and to prevent a repetition of the disastrous conditions which have befallen this country in the past, and which were believed by the framers of the Act to have been occasioned in a large measure by customs and methods heretofore pursued, and certainly no just criticism can be made of the acts of the Organization Committee in establishing the present district lines, when it is said, as it is said in the petition, that such action in a measure changed banking customs heretofore prevailing. STATEMENT UNDER PROPOSITIONS (a) to (g), IN CLUSIVE. See former Statement hereinbefore set out. 20 On page J 3.8, Senate Record, will be found the fol lowing : “ The unassailable fact is—St. Louis and Kansas City will not. dispute it—that when Texas needs money to move its crops, its banks can not borrow money in any considerable quantities in either St. Louis or Kansas City, and must go to Chicago or to the Atlantic sea board. Balances are kept in St. Louis now, not in order to secure loans there in time of need, nor because trade sets that way, but in order to secure exchange facilities and provide means for making collections at par. “ The re-diseoiuits and bills payable in the district Texas has defined, were $23,000,000 at the peak of the heaviest demand of 1913. How much duplication or pyramiding was in this sum it is not easy to say; but, as shown in the Dallas Book of Facts, more than threefifths of the amount could have been absorbed by the reduction in the percentages of reserve which are provided for under the law. The National banks in the territory would have had $15,000,000 more of loan able funds at that time, if the present law had then been in force, leaving only $8,000,000 to be taken care of by the regional bank. Its available funds for that purpose would have been far in excess of these demands. “ If the new law is simply going to provide new machinery (perhaps more complex than the old) for doing what is already being well done under the ex isting banking system, its importance and efficiency has been vastly exaggerated. We do not believe it is so limited in function. We think it was intended to pro vide elasticity and a means for equalizing seasonal in equalities, to relieve strain where strain has been great under the old system. It is, however, going to be a handicap instead of an advantage, if its effect will be normally to restrict Texas banks or banks in any other single district, to their regional bank and affect their open market connections. If it is going to be thought 21 a crime, or even bad banking, for one regional bank to use the surplus funds of another at one season, and to render the same service to another bank at another season, the law will prove to be absurdly inadequate. “ Moreover, why should it be thought inevitable th at the member banks will deal only with the regional bank when wanting to borrow money? No one doubts th at banks which now have resources beyond their local needs will continue to lend that money to other banks to meet seasonable requirements. If the new law is to create in the Government a monopoly of the busi ness of loaning money to National banks to meet their seasonable requirements, it has not been so advertised. Member banks will, of course, maintain their legal re serve with the regional banks, but they will deposit as in the past surplus funds with other banks, receiving interest on daily balances and having constant trans actions in the borrowing and loaning of money as here tofore.’’ On page 120, the following: “ Southern Oklahoma is identified with Texas in every way. Texas people settled it up; Texas buys its cotton; her cattle graze its ranges; Texas buys its stock, its gas, its oil and its lumber. Northern Oklahoma is divided, a p art preferring Kansas City, a part pre ferring St. Louis. Texas is closer to it, however, in every way, and can serve it better than any other State. “ No doubt there are many people in Louisiana, South western Arkansas and Oklahoma, who would prefer not to be put in the District with Texas cities. There are many, however, who favor the Texas district. Some violence must be done, for manifestly this committee can not please those holding such opposing views. The nearest possible reconcilement—if the endeavor is to be made to please everybody—would be, to put Southern Oklahoma with the Texas district and Northern Okla 22 homa with the St. Louis district, assuming, of course, that 110 bank is to be put a t Kansas City.” On page 112, the following: “ Nine trunk-line railroads radiating in 27 different directions, with 91 daily passenger train s: Chicago, Bock Island & Gulf Railway; Gulf, Colorado & Santa Fe Railway; St. Louis, San Francisco & Texas Railway; Houston & Texas Central Railroad; Missouri, Kansas & Texas Railway of Texas; St. Louis Southwestern Rail way of Texas; Texas & New Orleans Railroad; Trinity & Brazos Valley Railway; Texas & Pacific Railway. “ Five electric interurban railroads radiating in seven different directions, with 156 daily trains, handling 4,000,000 passengers annually: Northern Texas Traction Co., Southern Traction Co., Texas Traction Co., Eastern Traction Co., Dallas-Corsicana Traction Co. “ Dallas has headquarters and general offices for the Southwest, of the Western Union, Postal, and Mackay Telegraph Cos., with 262 circuits, handling 18,497,300 telegrams per year. Dallas ranks sixth in the United States in total volume of business. “ Dallas has headquarters and general offices for the Southwest of the Southwestern Telephone (Bell) Co., with 159 toll circuits, originating 554,000 long-distance calls per year, increasing at the rate of 50,000 calls per year; 2,924 toll stations operated from Dallas as head quarters ; 643 towns served from Dallas on 50-cent rate, 169 on 25-cent rate. Fifteen and nine-tenths per cent of all the telephones in Texas are in Dallas. “ Dallas has the largest telephone development per capita of any city in the United States. “ All express companies operating in the territory have headquarters at Dallas. “ Only six cities in the United States have a larger volume of express business than Dallas. “ Dallas has more express business per capita than any city in the United States. 23 “ Dallas has 176 mail receipts and 137 mail dis patches daily. “ Dallas has 111 daily exchanges of mail pouches direct with towns in Texas. Dallas has 65 daily mail dispatches to railway post offices. Dallas has 80 daily receipts of pouches direct to Dallas from other Texas cities. Dallas has 57 mail receipts daily from railway postoffice lines, exclusive of the 80 direct receipts from Texas. In reaching territory outside of Texas, Dallas has 57 receipts of mail and 65 dispatches of mail daily. “ While Dallas is the fifty-fourth city in size, its postal receipts are thirty-third in volume, and as much as any two cities in the territory combined.” On page 123, the following: “ M. H. Wolfe hais furnished the following cotton sta tistics : “ Cotton area of all the South, 892,072 square miles. “ Cotton area in 12 hours’ ride of Dallas, 437,794 square miles, or 49 per cent. “ Total cotton produced in South last year, 14,101.000 bales. “ Cotton produced in 12 hours’ ride of Dallas. 6,857.000 bales, or 481/£ per cent. “ Texas produced last year 4.902,000 bales. “ Oklahoma produced last year 1,057,000 bales. “ Arkansas produced south of the Arkansas River 505.000 bales. “ Louisiana produced 393,000 bales. “ Dallas cotton buyers bought last year 1,459.000 bales. “ Dallas cotton buyers have salaried men covering all sections of Texas, Oklahoma, Arkansas and Louisiana, and paid out for cotton last year approximately $92.000,000, and approximately $80,000,000 of this cotton was financed directly or indirectly by the Dallas banks.*' At the hearing before the Organization Committee in 24 Austin, Texas, on February 9, 1914, Thomas H. Ball, of Houston, testified before the Organization Committee, and while lie was testifying, the following interrogatories and answers were given: “ The Secretary of the Treasury: Suppose New Or leans made exactly the same argument you are making, that she did not want to be attached as a vassal to Texas, what is this Committee to do? There are various sections of the country that are arguing that they ought not to be attached to anything, they must be kept off by them selves, they do not want a re-united country on the fi nancial question; and so, if that argument is good here, it is good in other sections of the country we have visit ed, so we are bound to consider this question from the economic standpoint, having relation to all these parts of the whole, and that is the only way we can consider it. “ Mr. Ball. Yes, and I do not expect you to do it any other way. And if New Orleans puts up that kind of an argument, she is at perfect liberty to do so, and I -will not resent it; and I do not resent these people coming in from St. Louis and trying to make repre sentations, and do the best they could to get us in with them. “ After all, the responsibility will come back to you gentlemen who are charged with it, and you will give such attention to our representations and views and figures as you think they are worthy of. And though you slay us, we will still serve this administration. We gave up the tariff on our raw material, against the judgment of a great many without a murmur, and we are trying to do what is right, and we want to help you in your great task; but we certainly think, with a State of this magnitude, and this showing, which must appeal to you as reflecting some degree of credit upon our people and their resources, we do feel very deeply in earnest about this matter, and we think that, with 25 the Pacific Coast, conceding it to San Francisco—I do not want to be in the attitude of hostility towards St. Louis, and I had her on the list of the eleven cities that I thought ought to be given regional reserve banks, but I do think that Texas, with her position, her great geographical area, her tremendous resources, the manner in which she is forging to the front in every line, and the confidence of her own people, that she can take care of the situation; th at these points which have been sug gested by our committee and by the Dallas committee, will not be any more bitterly opposed certainly to being attached to Texas, than Texas will be to being attached to these other points, and I was just suggesting that be cause while we are amiable, we want to do all we can; we want you to consider as far as you can consistently with your enormous responsibility, the desires and wishes of this great State of ours. “ The Secretary of the Treasury: That is what we came here for, to get your views, and we are going to give fair consideration to every argument that has been presented. But I should like to say just this in answer to your remarks, that though we slay you, you will still be loyal to the administration, Colonel— “ Mr. Ball: Well, I mean the Government. “ The Secretary of the Treasury: I want to say that in that connection, of course I assume you are speaking facetiously, but somebody may not understand you, and therefore I do wish to say, that it is impossible, of course, in the laying out of these districts as required by law, to slay any section of this country, or injure any section, whatever these districts may be. This new system is bound to be more beneficial than what you have got today, so that while the desire of every local community will be impossible to meet, and if we allowed every community to lay out its own district, we would never get the country divided into these districts; the pur pose of the committee in having these hearings through 26 out the country has been solely to give the people of this country the largest and amplest opportunity to pre sent the views as they see them for our consideration; and we are going to give those views fair and impar tial consideration and our decision will be rendered from that standpoint, and no other. “ Mr. Ball: We know that, Mr. Secretary.” Mr. W. W. Collier, Commissioner of Banking and In surance of the State of Texas, testified before the Or ganization Committee at the hearing at Austin, Texas, on February 9, 1914, and, while testifying, the follow ing interrogatories and answers were given: “ The Secretary of the Treasury: We should like some information as to that, and also whether State banks, under your law, are entitled to become members in this system. “ Mr. Collier: Yes, sir, there is nothing in our law to prevent them becoming members. “ The Secretary of the Treasury: Is there, anything that authorizes them? Are they permitted to own stock? “ Mr. Collier: Yes. Under the statutory provision they can own not in excess of 10 per cent of the capi tal stock of the corporation in which they are investing. “ The Secretary of the Treasury: You mean 10 per cent of their own capital? “ Mr. Collier: No. 10 per cent of the corporation in which they are investing. “ The Secretary of the Treasury: That would seem to give them ample power. * * • * • “ Mr. Collier: There are 849 State banks in Texas, with a total capital, surplus and profits of $44,645,000. I will omit the odd figures. They have total deposits of $90,000,000 and total resources of $149,000,000. 27 “ The Secretary of Agriculture: W hat has been the growth in the last five years? “ Mr. Collier: The growth of the banks during the fiscal year 1912-1913, there were 111 new charters grant ed, with aggregate capital of $3,358,500. The growth of the deposits from the time the State Bank Law went into effect in 1906, was $8,000,000; 1907, $19,000,000; 1908, $22,000,000; 1909, $39,000,000; 1910, $48,000,000; 1911, $58,000,000; 1912, $71,000,000; 1913, $96,000,000. “ The Secretary of Agriculture: That is the growth in the last seven years? “ Mr. Collier: That is the growth since the system was established. “ The Secretary of the Treasury: How many are eligible under the Federal Reserve Act? “ Mr. Collier: 377, with an aggregate capital and surplus of $31,857,500. “ The Secretary of Agriculture: And deposits? “ Mr. Collier: I did not give the deposits, because I was not called on until this morning for this data, and did not have time to prepare that, but it is fair to assume that the deposits of those would be about $60,000 000 “ The Secretary of the Treasury: Have you any in dication from these banks as to their purpose with re gard to the Federal Reserve Act? “ Mr. Collier: I will say this, Mr. Secretary. I have had, I suppose, inquiries from almost every one, and the attitude of the Department of Banking in Texas is to encourage them to become members. “ The Secretary of the Treasury: Are they showing a disposition to come into the Federal Reserve system? “ Mr. Collier: I believe it is fair to assume that more of them would become members if a Federal Re serve Bank is located in Texas, than they would if it was located otherwise. “ There is one point I want to touch on, if you will pardon me. That is, it has been suggested that having , . 28 a Reserve Bank located in Texas, where it was entirely a borrowing country, would not be advantageous or wise. I want to say that if the banks used their re* serves, they would always be able to take care of them selves. At the date of the last call, our State banks in Texas only had four and one-half million dollars bor rowed, and had in Eastern Exchange over $14,000,000.” ARGUMENT. Petitioners state, on the first page of their p eti tion, their reasons for omitting the Counties of Bryan, Choctaw, Marshall, McCurtain and Pushmataha from their application to transfer certain territory in South ern Oklahoma from the Eleventh District to the Tenth District. Their reasons, as stated, may be correct, but a very sufficient and potent reason will also be found by ref erence to Exhibit F, 1 to 26, inclusive, in the Ap pendix, wherein will be found copies of letters from twenty-six member banks situated within this territory, stating most unequivocally that they are situated in the District of their preference. As shown in the Appendix, Exhibit “ G,” there are one hundred and sixty-six member banks in Southern Oklahoma within the Eleventh District. The Committee filing this petition have excluded from the term s of the petition the Counties of Bryan, Choctaw, Marshall, MeCurtain and Pushmataha. In these five counties there are thirty member banks, as shown by Exhibit G, in the Appendix, the name of each member bank being preceded by a star. Deducting these thirty banks from the number of member banks in Southern Oklahoma, there are left one hundred and thirty-six member banks. 29 In order for any territory to be transferred from one District to another, it is absolutely necessary, under the rules and regulations of this Board, for appeal from the decision of the Federal Reserve Organization Com mittee, that two-thirds of the member banks in the ter ritory sought to be transferred, join in the petition asking to be transferred from one District to another. Thus it will be seen that it requires a petition signed . by ninety member banks before this Board would have jurisdiction to hear any petition at all looking for a transfer of territory from the Eleventh to the Tenth District. Attention is here called to the fact that certain banks which filed protest slips with the Federal Reserve Board, some time before the opening of the Federal Reserve Banks have been listed by the Committee filing this petition as petitioning banks. The B oard’s atten tion is respectfully called to copies of letters from twen ty-two of these banks so listed as petitioning banks, found in the Appendix, marked Exhibit A, 1 to 22, inclusive, which letters show not only that these banks are not petitioning banks, but that the great majority of them are perfectly satisfied and want to remain in the Eleventh District, and that the remainder feel that no change should be made now, and that no effort should be made to change the lines until after the Federal Reserve Banks have been in operation a sufficient length of time to enable your Board to intelligently and prop erly determine whether or not the Federal Reserve Or ganization Committee made error when it established the present lines. On the last page of the petition will be found the 30 statements: ‘‘Total number of national banks in the territory sought to be transferred, 128. Total number of banks asking to to be transferred, 104. Two-thirds ma jority required by rules, 85.” . Each of these state ments is erroneous and misleading, and none of them can be accepted as correct. In the first place, there are 186 member banks in the territory sought to be trans ferred. In the next place, out of the 104 banks which the petition lists as petitioning banks, the Board will find, upon examination of Exhibit A, 1 to 22, in clusive, that twenty-two of these banks have, in effect, expressly stated that they are not petitioning this Board to make any transfer of this territory a t this time. In order for the Board to hear a petition from the banks in Southern Oklahoma, that petition, in accord ance with your regulations, must be signed by the duly authorized officials of ninety member banks. Respond ent has heretofore insisted, and now insists, th at this petition has never been authorized or signed by any banks in the territory sought to be transferred, w ith the exception of the City National Bank, of McAlester, and the First National Bank, of Lawton. The third man signing the petition does not even claim to reside in the territory sought to be transferred. If your Board overrules the exceptions heretofore urged and overrules the contention here made, th at no proper petition has ever been filed, in accordance with your regulations, then most certainly, when you deduct from the number of banks whieh this Committee states are petitioning banks, the twenty-two banks which have expressed a desire either to remain within the Eleventh District, or a purpose not to urge any change or trans 81 fer at this time, you will then have left only eighty-two banks, or eight less than the number required to file a proper and legal petition under the B oard’s rules and regulations. Attention is here called to the fact that whatever protest slips have been filed with your Board antedate the letters from the banks in Southern Oklahoma shown in the Appendix and referred to in this brief. Attention is farth er called to the fact that there are sixty-two letters from banks in Southern Oklahoma showing th at they are not in sympathy with the Committee filing this petition. Had not the five counties above mentioned been excluded from the territory sought to be transferred by this petition, it would have re quired one hundred and ten banks to file a proper petition under your rules. It is, therefore, apparent th at the Committee filing this petition were forced to exclude from the territory in the Eleventh District sit uated in Oklahoma certain Southern Oklahoma coun ties or th at it could not have claimed, even by referring to prior protest slips, to have filed a petition which could be considered at all under your rules. It will be noticed, from certain expressions found in the letters in the Appendix, that the reason first as signed by certain parties outside of the District why Southern Oklahoma should not be included within the limits of the Eleventh District was, that the State of Oklahoma was being divided. Appeals were made to the patriotism of the bankers in Southern Oklahoma to protest against the inclusion of Southern Oklahoma within the limits of the Eleventh District because, and 32 for the sole reason, as first claimed, th a t the State was being divided. Under the first proposition in petitioner's brief page 1, is found subdivision entitled, “ (a) Course of Business,” and the contention is there made th a t because the Oklahoma banks have heretofore done some business with Kansas City banks, therefore the course of busi ness was to Kansas City, and that, for this reason, the transfer of territory should be granted. In order to properly analyze the contention made by petitioners, it is necessary to view the circumstances which forced the course of the banking business to take the unnatural trend and not follow the course of commerce. Under the old law, St. Louis was a central reserve city, and Kansas City was a reserve city. Chicago, New York, and other Eastern cities were central reserve, or reserve, cities. This condition prevailed for a great number of years before the development of the great Empire State of Texas. Kansas City, St. Louis, Chicago, and other cities were reserve cities for a number of years prior to the establishment of any reserve cities in the State of Texas, and, under the then existing law, it was incumbent upon the banks to carry balances in the reserve cities. Therefore, Oklahoma banks, Texas banks, Louisiana banks, New Mexico banks, and Arizona banks, and a great many other banks in the Southwest, were forced to carry balances and do business through Kansas City and St. Louis, because of the advantages those cities had by reason of being reserve cities; and this business, which the petitioners state is the natural course 83 of business, was built up by virtue of this condition just mentioned, which forced the trend of the bank ing business to be to Kansas City and St. Louis, rather than to follow the commerce, which was to the South and Southwest. It may be conceded that a great many banks in Southern Oklahoma heretofore, have done and now do, business in Kansas City, but the conceding of that point does not necessarily show an error in judgment on the p art of the Organization Committee. The Federal Re serve Act does not force these banks to discontinue car rying balances in Kansas City, if they find it to their advantage to do so, but simply requires them to also carry part of their reserve in the Federal Reserve Bank of their District. Instead of working to the disadvantage of the banks in Southern Oklahoma, this Act works to the distinct advantage of these banks, in that it permits them to re tain a banking connection in Kansas City and opens for them a very valuable banking connection with the Reserve Bank in Dallas, in the very locality where their products are marketed and paid for. On the first part of the second page of petitioners* brief, is found certain figures claimed by the petitioners to support their theory as to why the transfer of this territory should be made. These figures are not new. They were known to the Organization Committee, and are readily explained in the light of what has heretofore been said with reference to the forced banking con nections heretofore existing at Kansas City and St. Louis, and other Reserve cities. 34 On the seeond page of the petition is found t t a following: “ We invite the attention of your B oard especi ally to a perusal of the letters from which these figures were tabulated, as many of them show the dissatisfaction existing among the bankers in South ern Oklahoma, and their evident desire to be in cluded in the Kansas City D istrict.” Such letters therein referred to are not accessible1 to respondent and are not found in the record of the1 Organization Committee, and constitute new testimony, introduced on this hearing for the first time, in violation of the regulations of the Board, and cannot be consider ed; but, if considered, and if, as stated by petitioners, these letters show dissatisfaction among some bankers with the establishment of the lines, then the question arises, whether or not this is simply a bankers’ law, or if this law shall be permitted to perform the functions which its authors and friends claim fo r i t ; th a t is, to be a benefit and relief to the business of the en tire country. It may well be here suggested, that it would be im possible, indeed, to frame any law with reference t o 1 banking matters, which would please all bankers. In fact, when this law was first proposed, a great many: bankers were against it in its entirety,. and this same dissatisfaction, which petitioners state these le tte rs ; show, may grow out of the dissatisfaction held by cer tain bankers to the law itself. Because some banks in Southern Oklahoma have here-1 tofore done business with Kansas City, does not show , that that is the natural trend of business, but the porl 35 titioners themselves in the brief, show that the trend of business, th at is, the trend of commerce itself, is not in the direction of Kansas City. Everybody else’s business except the bankers’ business, goes to the South and Southwest, and, therefore, the Dallas Bank is in line with the trend of the commerce and business from Southern Oklahoma. The next subdivision of petitioners’ brief, entitled “ Oklahoma-Dallas Relations,” page 2, refers to a letter from Mr. Thralls, manager of the Kansas City Clear inghouse, which letter we are unable to find in the record of testimony taken by the Organization Committee and we, therefore, naturally conclude that this letter is also new testimony furnished by the petitioners for the first time. But what has been above said with reference to the course of business, in our opinion, completely answers this contention of the petitioners, and the contention itself, we submit, is not Avorthy of any serious con sideration. : In this connection, we desire to call the B oard’s at tention to a portion of the testimony set out under our second statement above, which will also be found on page 318, Senate Record, and is as follows: “ If the new law is simply going to provide new machinery (perhaps more complex than the old) for doing what is already being well done under the exist ing banking system, its importance and efficiency has been vastly exaggerated. We do not believe it is so limited in function. We think it was intended to pro vide elasticity and a means for equalizing seasonal in equalities, to relieve strain where strain has been great under the old system. It is, however, going to be a handicap instead of an advantage, if its effect will be normally to restrict Texas banks or banks in any other single District to the Regional Bank and affect their open market connections. * # * “ Moreover, why should it be thought inevitable that the member banks will deal only with the Regional Bank when wanting to borrow money? No one doubts that banks which now have resources beyond th eir local needs will continue to lend th at money to other banks to meet seasonable requirements. If the new law is to create, in the Government a monopoly of the busi ness of loaning money to National banks to meet their seasonable requirements, it has not been so advertised. Member banks will, of course, maintain their legal re serve with the regional banks; but they will deposit as in the past, surplus funds w ith other banks, re ceiving interest on daily balances and having constant transactions in the borrowing and loaning of money, as heretofore.” This quotation is from the record of the Organization Committee, and, of course, it would be absurd to suggest that the Organization Committee did not give due con sideration to this statement, as well as the other facts introduced, before it at its numerous hearings, and it is apparent, from a careful reading of the Federal Reserve Act, that its purpose was not to lim it member banks to Federal Reserve Banks, but was enacted for the purpose of giving the member banks the benefit of the new facilities in addition to the facilities they had already enjoyed. On page 3 of petitioners’ brief is found subdivision entitled as follows: “ What Dallas Bankers Say.” Under this heading, reference is made to letters from two banks in Dallas, which letters, from their dates, 87 show to have been written after the hearing of the Or ganization Committee, and which letters are not found in the record before the Organization Committee. The letters, however, when read and considered, form no basis upon which to predicate the argument th at the Federal Reserve District lines should be changed. If Dallas banks have not sought business from Oklahoma banks, it may be to the disadvantage of the Dallas banks, but it certainly does not show a reason for trans ferring territory situated at the door of the Dallas Re serve Bank, to a bank situated several hundred miles away. On page 3 of petitioners’ brief is found subdivision entitled: “ What Freight Shipments Show.” The state ments made by the petitioners under this heading re fute the contention that the trend of business is to Kansas City, but show that it is to the Southwest, or towards the Gulf. In this connection, reference is here made to a letter from Sam I. Qynds & Company, cotton merchants and members of the New Orleans Cotton Exchange, to B. A. McKinney, which letter, marked Exhibit D and found in the Appendix, shows that practically all of the cotton produced in Oklahoma, sold for export and to New England mills, passes through Texas ports or New Or leans, and further shows that the farmers and mer chants who ship cotton on consignment, forward same to Houston, Galveston and New Orleans. Reference is also made to letter from Frank Kell, reputed to be the largest grain operator of the South, west, to B. A. McKinney, designated as Exhibit E, 38 which shows that practically ninety per cent of the grain, such as wheat, oats and corn, raised in Southern Oklahoma, moves southward, and is consumed in Texas and Louisiana, or moves out through the Gulf ports. We submit that these two letters are new testimony, but they are only used to refute the new testimony ad duced on this hearing, and which was not adduced on the hearing before the Organization Committee. It is absurd to say th at the freight rates to Gulf ports in Texas and Louisiana are not lower than they are to the Northern and Northeastern m arkets from South ern Oklahoma, because it is a self-evident fact th a t com merce follows the trend of lower rates. If there were equally as good markets for cotton and grain in Kan sas City, St. Louis and Eastern points, and th e rates to those markets were lower than to Gulf ports, it would then be natural that the commerce flow in those direc tions, instead of through Texas, and to the Gulf. We have not felt that it was necessary to set out the different freight rates on these commodities, because, whenever it is shown to this Board, th a t the commodities themselves move to the Gulf and Gulf ports, it then be comes evident that the freight rates in th a t direction must be the favorable rates. On page 4 of petitioners’ brief is found subdivision entitled: “ Showing of Farm Loan Companies.” Un der this subdivision, reference is made to letters show ing that Eastern money had been used fo r farm loans in Oklahoma. We have no doubt but what th a t statem ent is true, although this fact is not shown in the only record to which we have reference; th at is, the testim ony before 39 the Organization Committee; but, granting that East ern money is loaned on Oklahoma farms, does that show any good reason why the portion of Oklahoma South of the Canadian River should not be included within the Eleventh Reserve District, with its bank lo cated at Dallas? Will the inclusion of this territory within the Eleventh District in the least manner pre vent a continuation of loaning of money on Oklahoma farms by Eastern capital if it so desires? It is not contended that these farm loans are made from Kansas City, but they are made in Oklahoma as well as in the entire Southwest, by parties all over the Eastern States, and certainly the fact that part of Ok lahoma is in the Eleventh District, with its bank at Dal las, cannot, in the remotest degree, affect this character of business. On the fourth page of petitioners’ brief is found subdivision entitled: “ (b) Convenience in Doing Busi ness.” Under this subdivision, petitioners contend that, because Southern Oklahoma banks have heretofore done some business with Kansas City banks, therefore the of ficers of the Kansas City Bank would be in better posi tion to find out about the Southern Oklahoma banks, and would render quicker service than the Dallas Bank. Of course, this contention, followed to its logical conclusion, is an indictment of the entire theory of the Federal Reserve Act. Under this heading is found the following: “ The situation at present is such, owing to this acquaintanceship, that any good bank in Southern Oklahoma will be granted a re-diseount immediately upon application to its Kansas City correspondent; 10 whereas, an application to a new bank to the south of Oklahoma would result in delay, in many cases, until an investigation could be made, and as these applications for re-discounts in the future will doubtless be made at times when prom pt action is necessary, another reason is afforded why these banks should be attached to the Kansas City Dis trict.” If the applications for loans th at petitioners refer to are to be granted by the correspondent banks in Kansas City, then certainly the inclusion of Southern Oklahoma in the Eleventh District would not affect the Kansas City correspondent ’s knowledge of the Oklahoma banks so applying for loans, and this contention, when analyzed, falls of its own weight. If the point sought to be made by petitioners is that, by reason of the fact that the Kansas City banks are acquainted with the Southern Oklahoma banks and that, by reason of that acquaintance, they would fu r nish the Federal Reserve Bank a t Kansas City w ith information regarding the Southern Oklahoma banks, then a complete answer to that proposition is th a t the Kansas City banks do not possess an absolute monopoly of knowledge regarding Southern Oklahoma banks, and th at the same information which they have has been and is readily obtainable by the Dallas Reserve Bank, when making investigation of the solvency and condi tion of Southern Oklahoma banks. A n analysis of the re-discounts made by the Dallas Beserve Bank will explode this proposition in an in stant. There are 757 member banks in the Eleventh Beserve District. Out of this number there are 166 banks in Southern Oklahoma. Reference is here made 41 to reports filed with this Board by the Federal Reserve Bank of Dallas, which show that the Federal Reserve Bank, of Dallas, out of the total amount re-discounted by it, has furnished re-discount facilities to Southern Oklahoma banks of more than twenty-five per cent of the total. Thus it will be seen that this apparent hardship which petitioners dreamed would develop, has not de veloped, but has faded in reality, when put to the test suggested by petitioners. On the fifth page of petitioners’ brief is found sub division entitled: “ Mail Facilities.” Petitioners there contend th at Southern Oklahoma should have been in cluded in the Kansas City District, because of the mail facilities. In support of this contention, reference is made to testimony not accessible to respondent, because not found in the record of testimony taken by the Organiza tion Committee; but an analysis of the position so taken by petitioners shows that the contention is absolutely unfounded and that the weight of the testimony accessi ble to your Board and to respondent establishes the fact that, instead of the mail facilities from Southern Okla homa points to Kansas City being better than to Dal las, the reverse in fact is true. Reference is here made to a letter from W. S. Cross. President of the State National Bank of Hollis. Okla homa, to the Federal Reserve Board, dated January 15, 1915, designated and shown as Exhibit A-14. fouud in the Appendix, reading as follows: “ In regard to the proposed change in this Re serve District, we prefer to stay in the Dallas Pis- 42 trict, on account of the distance and connection* which the mails make. We are only twelve hours from Dallas, and about forty-eight from City.” This letter is from the President of a bank which has been listed as one of the petitioning banks asking fo r this transfer. We refer further to a portion of the first statem ent set out above, wherein there is a quotation from page 116 of the Senate Record, reading as follow s: “ The map attached will show th a t all of th e te rrito ry claimed in Oklahoma, Arkansas and Louisiana, is w ithin 15 hours by rail from Dallas. T hat every portion of th e territory can be reached from Dallas in less tim e th a n from St. Louis. W ith the exception of a sm all portion of northern Oklahoma, north of th e Canadian R iver, it can be reached from Dallas by ra il in shorter tim e th a n from Kansas City.” Attention is called to the fact th a t no p a rt o f N orth ern Oklahoma, north of the Canadian River, is in cluded in the Eleventh Reserve District, and th a t, th ere fore, by the testimony here shown and considered by the Organization Committee, it is absolutely established, beyond any controversy, th a t all of the te rrito ry In Oklahoma included within the Eleventh D istrict, is shorter distance by rail from Dallas th an i t is from Kansas City. A ttention is further called to a portion of the first statem ent found in respondent’s brief, quoting from pages 117 and 118 of the Senate Record, reading as fol lows : ‘‘W ith the exception of some territory in the ex treme western and southern portions of the District/ 48 and a small area in southwestern Louisiana, every point in the D istrict is within twelve hours’ mail service of Dallas.’* If further argument is necessary to refute this con tention of petitioners, the Board will only have to turn to the maps on file with them, and look at the terri tory in Southern Oklahoma sought to be transferred, when it will be seen at a glance that this territory is almost at the door of the Dallas Reserve Bank, and is several hundred miles from Kansas City. On page 5 of petitioners’ brief is found subdivision entitled, “ Loan and Discount Facilities,” from which we quote: “ Second. In the second place. Southern Okla homa should be placed in the Kansas City District, because the figures show the Kansas City District will be better able to meet the re-discount re quirements of the Southern Oklahoma banks, than will the Dallas D istrict.” Reference is here made to the testimony set out in the second statement above of respondent, being a quota tion from page 118 of the Senate Record, as follows: “ The unassailable fact is—St. Louis and Kansas City will not dispute it—that when Texas needs money to move its crops, its banks can not borrow money in any considerable quantities in either St. Louis or Kan sas City, and must go to Chicago or to the Atlantic sea board. Balances are kept in St. Louis now, not in order to secure loans there in time of need, nor because trade sets th at way, but in order to secure exchange facili ties and provide means for making collections at par. “ The re-discounts and bills payable in the District Texas has defined were $23,000,000 at the peak of the 44 heaviest demand of 1913. How much duplication or pyramiding was in this sum it is not easy to say ; but, as shown in the Dallas Book of Facts, more th a n threefifths of the amount could have been absorbed by the reduction in the percentages of reserve which are pro vided for under the law. The National banks in the te r ritory would have had $15,000,000 more of loanable funds at that time if the present law had then been in force, leaving only $8,000,000 to be tak en care of by the Regional Bank. Its available funds fo r th a t p u r pose would have been far in excess of these dem ands.” It will thus be seen that the only testimony introduc ed before the Organization Committee, and which is the only testimony that can be considered by this Board, refutes in toto the contention made by petitioners. As further bearing on this point, reference is now made to a portion of the first statem ent of respondent, quoting from page 118 of the Senate Record, as follow s: “ For eight months in every year a Regional B ank in this District would have money to lo a n ; for twelve months in an ordinary year it could take care of its own member banks and have money left. D uring the exceptional year (1913) just passed, it could a t the peak of its advances to member banks, have financed itself. If, however, under extraordinary stress it should need to re-discount the receivables of member banks to a small extent with other Regional Banks, or to issue emergency currency, it would simply be making use of these features of elasticity which have been advertised as among the chief excellencies of the new banking law. “ If the Texas Regional Bank should be a lender bank eight months out of every year and twelve months out of an ordinary year, why should it not every four months during an occasional extraordinary year, be a borrower or note-issuing bank?” 45 Under the terms of the Federal Reserve Act, the Re gional Banks cannot reach the height of their efficiency for a period of three years. At present they are operat ing only with a portion of the capital provided by the terms of the Act. Before tearing up these Districts and crippling the Bank of the Eleventh District in its opera tion, would it not be the part of wisdom to wait a sufficient length of time until the Dallas Bank could, in a measure, reach the height of efficiency made possible for it by the terms of the Act? At this time there is nothing to indicate that the grounds of fear entertained by the petitioners will ever materialize. To act now would be a step in the dark, and would be to anticipate a condition when there is nothing to justify an expectation of its realization. Al though the Dallas Bank has not, in the smallest degree, reached the height of its efficiency, yet, at this time, all of the legitimate wants and needs of the Southern Oklahoma banks are being taken care of as fast as they are suggested. Suppose, in an exceptional year, it should become necessary for the Dallas Bank, in order to move the great cotton crop of its District, to re-discount the re ceivables of its member banks to a small degree with other Regional Banks, would this constitute a crime, or would the Bank then be simply putting into operation the very terms of the law under which it was created? The testimony which this Board must consider does not show that even it will be necessary to do this; but. it' an extraordinary period should come and this became necessary, would not this course be much better than the tearing up of the present District lines and the in- 46 elusion of Southern Oklahoma in the Kansas City Dis trict, where admittedly there is no need for additional territory! What we have just said above, in respondent’s opinion, completely disposes of what has been said bypetitioners under subdivisions headed: “ Heavy Dallas Re-discounts,” “ Transfer Would Help Both D istricts,” and “ Comparative Loaning Resources,’’ found on pages 6, 7 and 8 of the petition. Ou page 8 of the petition is found subdivision en titled: “ How Proposed Change Would Benefit.” Petitioners have already attempted to show to this Board that the Dallas Bank lacks the resources to care for its member banks in Southern Oklahoma, and yet they have the temerity to propose to fu rth er reduce the resources of the Dallas Bank, and, by so doing, the claim is put forward that this action would help both banks. If the Dallns Bank, with the inclusion of the 166 mem ber banks in Southern Oklahoma, does not have sufficient resources lo meet the dire conditions which petitioners profess to see in the future, then, in respondent’s opinion, it is a strange course of reasoning to say th at, if you weaken this already claimed weak bank by taking from it almost one-fourth of its means of available resources, you wiU, in that maimer, help the already claimed weak bank. Respondent does not, for an instant, concede th a t the Dallas Bank will not have resources to care for all of its member banks in Southern Oklahoma and else where, but simply points out the fallacy of the reasoning 47 of petitioners under the heading: Change Would Benefit.” “ How Proposed The proposition is here laid down that, under the testimony taken by the Organization Committee, the Dallas Bank, with the inclusion of the Southern Okla homa banks, will have adequate resources to care for the legitimate needs and necessities of each of its member banks. It has just been shown that this Bank could have cared for all of the needs of its member banks for the year 1913, which was one of the heaviest borrowing years in the history of the Southwest. If the petition is denied and the Bank of Dallas is permitted to work out its problems in the manner pre scribed by the Federal Reserve Act, in respondent’s opinion, time will show that not only have the petitioners been in error as to their claimed foresight of calamity, but that the Dallas Bank will become one of the strong est institutions created by this Act. The next subdivision of the petition is headed: ‘‘Pro tests of Banks Practically Unanimous.” Under this subdivision, the contention is made that banks in Southern Oklahoma were practically unani mous in protesting against the present District lines. It is there shown that W. B. Harrison, Secretary of the Oklahoma Bankers’ Association, and a resident of Okla homa City, sent out a letter to the banks in Oklahoma, asking them to sign protest slips and return to him. It is claimed that 309 banks signed protest slips, indicat ing their displeasure at the establishment of the pres ent lines. If 309 banks in Southern Oklahoma signed such pro test slips, th«»n there was either some duplication or 48 error has been made in the count. There are only 166 member banks in Southern Oklahoma. P etitioners them selves, for reasons which they found sufficient to them selves, excluded the banks in five counties, leaving only 136 member banks in the te rrito ry w hich peti tioners ask to be transferred. O ut o f th is num ber, 32 admittedly, according to the petition, n ever filed any protest. Of the rem aining 104, tw enty-tw o have since that time indicated either a preference to rem ain in the Dallas District, or a desire to see no change m ade a t this time. Thus, it will be seen th a t, upon ca refu l scrutiny, this contention cannot stand. The next tWo subdivisions fo u n d brief, are headed-. in p e titio n e rs ’ “ P ro test o f M illers’ O rg a n isa tio n ” and “ Transfer W ould N ot In ju re D allas B a n k .” W hat has already been said, in re s p o n d e n t’s opinion, completely disposes of th e contentions m ad e u n d e r th ese two headings. The next and last subdivision in p e titio n e rs ’ brief, is headed: “ Oklahoma A sks O nly P a i r P la y .” Under this heading it is s a id : “ It is the belief of th e b a n k e rs o f O klahom a, th a t the present division of th e S ta te w ill o p e ra te to hamper the upbuilding o f th e fin an c ial in te re sts within the State, through th e d iv ersio n fro m O k la homa financial centers o f b a n k b u sin ess to w h ieh they are legitim ately entitled, b y re a s o n o f th e fact that many bankers will feel com pelled to o p en accounts in Dallas, o th er th a n w ith th e F e d e r a l Reserve B ank.” It is here suggested th a t w hen the Committee filing 49 this petition prepared the petition, it saw fit, for rea sons of its own, to divide the State and to leave five coun ties of Oklahoma in the Eleventh District. If the di vision which the Organization Committee made of the State of Oklahoma when it established the present lines was hurtful to the State of Oklahoma, why does it not follow that, by the same course of reasoning, the divis ions which the Committee filing this petition makes of the State of Oklahoma would be equally as hurtful? The above quotation shows that probably some finan cial center feels that its territory has been encroached Upon by reason of the establishment of the present Dis trict lines. It may be possible that there is more under the surface than the above statement would show. In a letter from the First National Bank of Col bert, Oklahoma, to the Federal Reserve Board, dated June 15, 1914, the following is found: “ I understand that bankers of Oklahoma City are making an effort to transfer us to Kansas City. I wish to protest against any change being made, as I feel that it is to our interest to remain as we are” (See Exhibit F -ll). Reference is here made to a letter National Bank of Frederick, addressed Reserve Board, under date of January m the Appendix, designated Exhibit C-4, following is quoted: from the First to the Federal 8, 1915, found from which the “ It is my opinion that this movement was insti gated by Oklahoma City bankers, and is being pushed on account of Oklahoma City parties, and not for the welfare of the majority of the bankers in the District. We are highly pleased with the 50 selection of Dallas as the reserve ce n te r o f th is Dis trict, and hope th a t no change w ill be m ade in the present D istrict lines.” Reference is fa rth e r m ade to a le tte r w ritte n b y the F irst National B ank of Kiowa, addressed to th e F ed eral Reserve Board, dated A ugust 14, 1914, fo u n d in the Appendix, and designated as E x h ib it C-7, re a d in g as fol lows : “ R eferring to th e efforts o f O klahom a C ity to change th a t p a rt o f O klahom a th a t is in F e d e ra l Reserve D istrict No. 11 fro m th e D allas to th e K an sas City D istrict, we a re pleased w ith th e D istric t as made, an d feel th a t th e business o f S o u th e rn O k lahoma can be best h an d led th ro u g h th e D a llas D is trict, and desire to p ro te st a g a in st th is ch an g e being m ade.” Reference is further made to a letter from the Tisho mingo National Bank, directed to the Federal Reserve Board, dated June 15,1914, found In the Appendix, and designated C-13, from which letter we quote as follow s: “ I notice from the press that there w ill be a com mittee of bankers from Oklahoma to appear before you in an effort to get all of* the State o f Oklahoma placed in the Kansas City Federal Reserve D istrict. This committee will doubtless represent that 95 % of the banks of Southern Oklahoma o f the D allas Reserve District are protesting against being le ft in the Dallas District, and probably there are a ma jority of banks South of the Canadian River on record as protesting against the division, but I wish to submit that the majority of these protests have been made as a direct result of a persistent campaign waged by Oklahoma City bankers. These Oklahoma City bankers have emphasized the fact 51 th at our State has been divided and put into two different Districts, while, under the present condition, our State is divided into a dozen or more different Districts. Some of us borrow our money from and keep our reserves with New York, while others are with St. Louis, Chicago, Kansas City, F ort Smith, Little Rock or various other centers. * * * The Oklahoma City banks sent out the protests all ready to be signed up by the different banks, and urged th at every bank join in the protest.” Quotation is now made from a letter from the Du ra n t National Bank, directed to the Federal Reserve Board, dated June 13, 1914, the letter being found in the Appendix, designated Exhibit F-12: “ We believe that a large p art of the sentiment manifested by some of the banks in Southern Okla homa in desiring to be transferred to the Kansas City District is due, in a great measure, to the agita tion brought on by Oklahoma City. They are in the Kansas City District themselves, and, believing that benefit would accrue to their own city by having Southern Oklahoma transferred to Kansas City, have conducted a vigorous campaign to bring about that result.” We quote further from a letter written by W. T. d a r k , President of the F irst National Bank of Apache, dated August 31, 1914, to Oscar Wells, Houston, Texas, letter being found in the Appendix, and designated A-4, as follows: “ Naturally we are in close touch with Oklahoma City bankers, and they are very desirous to get the lines changed. I have not heard lately of any action being taken in the matter. In our dealings with a regional or reserve bank, I do not see that it makes very much difference whether the bank is located 52 in Dallas or Kansas C ity; however, as sta te d above, our business relations with Texas points have been very limited.” On page 2 of the petition is a statem ent to th e effect that the parties filing the petition h ad never seen rep resentatives of Dallas banks a t the Oklahom a B an k ers’ Convention until the last one in May, 1914, ju s t a fte r the announcement was made of the present D istrict lines. The committee filing the petition have seen fit to testify to this fact, and we, therefore, presum e th a t it will be legitimate if we do a little testify in g also w ith reference to the presence of Oklahoma C ity ban k ers at Dallas; and, as a m atter of inform ation, an d as th ro w ing light on the immediate question un d er discussion, i t is here stated that, upon the occasion of th e m eeting of the representatives of all of the banks in th e E leventh District at Dallas, on May 30, 1914, fo r th e purpose o f nominating candidates for th e several directorships in the Eleventh District, a delegation of O klahom a C ity bankers was in attendance, and was present a t a caucus held by Southern Oklahoma bankers the d ay previous to the general convention. These gentlem en from O kla homa City had prepared and brought w ith them a reso lution which they asked the Oklahoma bankers to adopt, to the effect that it was the sense of the caucus th a t Southern Oklahoma should be tran sferred to the K a n sas City District. Great pressure was brought to b e a r in th eir efforts to get this resolution adopted, b u t th e caucus of Southern Oklahoma bankers voted down th e resolu tion. It is, therefore, apparent from the statem ent an d 53 letter quotations above, th a t Oklahoma City has more than a passing interest in this contest. If it has an in ter est in the contest, of course, the Board hearing the con test is entitled to know th a t Oklahoma City has mani fested some concern over the change of lines, and if the contest was instigated through the efforts of Okla: homa City bankers, and was not a voluntary move upon the p art of Southern Oklahoma banks, this fact will, of course, be duly weighed and considered by the Board. It is more than evident th a t the bankers of Oklahoma City are not neutral onlookers in this contest, but th a t they have, from the beginning, violated the laws of neutrality, and at times have taken an open and vigor ous position for a change in the present D istrict lines. That fact being established, it, of course, becomes p erti nent to find a reason for this violation of neutrality upon the p art of Oklahoma City bankers. This activity upon the p art of the Oklahoma City bankers may have been brought about by reason of a well defined idea th at these bankers may entertain that Oklahoma City would be an excellent place for the des ignation of a branch bank of the Kansas City Bank in the event the Oklahoma City bankers should be suc cessful in bringing about a change of the present D istrict lines, as prayed for in the petition. Respondent does not imagine that it would be hard to convince Oklahoma City bankers that their city would be an excellent point for the designation of a branch bank. Indeed, that ambition on the p art of Oklahoma City is a worthy and commendable one, but should not. in our opinion, out weigh the facts hereinabove presented. It has already been abundantly shown that the grain 54 products of Southern Oklahoma pass into Texas and Louisiana and th at the surplus not consum ed thm-frfa passes out through the Gulf ports in these States, an d that the cotton from Southern Oklahom a all passes through Texas and out through th e G olf p o rts o f Texas or Louisiana. The wisdom of the Organization Committee, therefore, becomes more manifest when it is considered th a t th e financing of the cotton crop during th e progress of p ro duction and while being m arketed, is a problem a n d a burden to the banker, not understood o r ap p reciated by those living in sections outside of th e cotton d istrict. Generally speaking, the business of a cotton com m unity ebbs and flows once in a year, necessitating p erio d s o f expansion which m ight not appeal favorably to persons not conversant w ith conditions which produce them . I t is therefore apparent th a t th e F e d e ra l R eserve Bank of Dallas, managed as i t is an d as i t necessarily will continue to be, by a B oard of D irectors w ho h a v e an intimate knowledge of th e cotton industry, can b e tte r serve the banks of Southern Oklahoma th a n th e K an sas City Reserve Bank, which is operated b y d irecto rs a n d officers who, though thoroughly qualified in a g en e ral way and properly disposed toward th eir m em ber b an k s, cannot, of course, understand the needs of a b a n k in a cotton growing region. If weight and credit is given to the argument of the petitioners that, because the Southern Oklahoma banks have, in a large masure, done business with banks in Kansas City, therefore, Southern Oklahoma should be transferred to the Kansas City District, then, by the same course of reasoning, Texas and Louisiana should 55 have been a ttac h ed to th e New Y ork D istrict, because the financing of th e Texas an d L ouisiana b anks h ereto fore has been la rg e ly th ro u g h New Y ork. The p e ti tio n in g com m ittee’s arg u m e n t co n tin u ed to its logical conclusion, w ould necessarily lead to th e re su lt th a t th ere should be only one F e d e ra l R eserve B ank, an d th a t a ce n tral in stitu tio n located in New Y o rk C ity. T he F e d e ra l R eserve A ct, in th e opinion o f th e m a jo rity of th in k in g m en, is th e g re a te st piece of c o n stru c tiv e legislation placed u pon th e s ta tu te books w ith in a p eriod of fifty y ears. I f p ro p e rly w o rk e d out, panics such as th is c o u n try h as suffered in th e p ast w ill d is ap p e a r as a m ist before th e risin g sun. T he A ct w as in ten d ed as a benefit a n d a sta y fo r th e business o f th e U n ited S tates. T he success of th e A ct now dep en d s upo n th e p a trio tic co-operation of th e b a n k e rs th ro u g h o u t th e co u n try . I f th e b an k e rs of th e U n ited S ta te s w ill hold u p th e h an d s o f th e F e d e ra l R eserve B o ard a n d th e officers an d d irec to rs o f th e F e d e ra l R eserve B anks, th e success of th is leg islatio n is a lre a d y assu re d an d th e blessings an d benefits flow ing th ere fro m w ill be w id e sp re ad an d su b stan tial. If, how ever, th e tim e of th e F e d e ra l R eserve B o ard is to be ta k e n u p b y co n tests betw een jealous com m unities, th e success of th is le g is latio n w ill be jeo p ard ized an d th e benefits a risin g th e re fro m w ill be m ateria lly dim inished. R espondent, th ere fo re , subm its th is m a tte r to th e ca refu l co n sideration of th e B oard, u pon th e re c o rd m ade by th e O rg an izatio n C om m ittee, firm ly believing th a t t)ie action of th e O rg an izatio n C om m ittee in e sta b lish in g th e present lines w as co rrec t an d p ro p el’, an d will re su lt beneficially to lmlli D istricts. 56 The original letters referred to in th is b r ie f a re b e ing filed with the Secretary o f the F e d e r a l R e se r v e Board for the use and benefit of the B oard. Respectfully submitted, CHARLES C. HUFF, Counsel fo r The F e d e r a l R e se r v e Bank of D allas, T ex a s. APPENDIX 59 MR. OSCAR WELLS, First National Bank, Houston, Texas. My dear Mr. Wells: I am in receipt of your letter of August 29th, relative to a movement on the part of certain Oklahoma bankers to have the Southern portion of Oklahoma removed from Dallas Reserve District and placed in the Kansas City District. I think that 1 got into disfavor with the Oklahoma bank ers immediately after the designation of this District, by reason of my publishing my opinion of the District, which was: “That it was very pleasing to me as it was arranged.” Afterward, considerable pressure was brought to bear on Mr. Norris and myself, in which an appeal was made to our patriot ism to the State of Oklahoma, and after it had gotten down to the point where we were told that every other bank in Oklahoma besides the First National of Ada and one other, had signed the request that all of Oklahoma be placed in the Kansas City District, 1 was prevailed upon to sign such a request. You may feel assured that I will do nothing whatever to have the boundaries of this District changed. I am enclosing you with this a circular letter that I have just received from W. B. Harrison, Secretary of the Okla homa Bankers Association, wherein you will note that Comp troller Williams has decided, after a full consideration of the matter, that no currency association will be formed in Okla homa, and has advised all banks to join the currency asso ciation in their District. It rather strikes me that this is al most equal to a decision against changing the Reserve District as already established. 1 appreciate hearing from you, and when I can be of further assistance to you in this country, it will be a pleasure to me. With kindest regards, 1 am, Yours truly, Enc. A. G. ADAMS AGA-RHQ President. 60 THE OKLAHOMA BANKERS ASSOCIATION. Office of the Secretary. Oklahoma City, Okla., Aug. 31, 1914 (IX) TO O. B. A. MEMBERS: After thoroughly discussing the matter, the Executive Com mittee has decided there is little the Association as a body can do to help out the cotton situation. It is a problem for each individual banker to work out. No one knows yet what the price of cotton will be when the Oklahoma product comes on the market; it may be lower or higher than the price in Texas, which now ranges from 7% to 9 cents. Most of the propositions put forward for holding the cotton crop INDEFI NITELY are believed to be impractical, but it is important to market the crop slowly, and where the farmer is in a position to hold some of the crop over, he should be encour aged to do so. Oklahoma has a very liberal warehouse law, and cotton warehouses, bonded, should be arranged for in every important cotton shipping town. This will help the farmer and the banker alike. Warehouses will make it pos sible for the banker to obtain accommodations he could not otherwise secure from his correspondents, and especially from the regional reserve banks. Bankers fthogld seize the present opportunity to induce the cotton farmer to get away from that crop into diversified farm ing and live stock. Comptroller Williams h at advised all National Banks to join the nearest currency association* and many Oklahoma banks are Inquiring whether such an association will be formed in Oklahoma. Full consideration of the matter has resulted in a decision in the negative. It would require almost the entire number of eligible banks in the Oklahoma portion of the Kansas City District to obtain the necessary capital for such an association, and it is doubtful whether the Comp troller would approve of its organization. It is already known he does not approve of crossing District lines. Hence, banks in the Kansas City District should join the Kansas City Asso ciation, and those in the Dallas District, the Texas Associa tion, if they desire emergency currency. There is danger of getting too much of this currency on the market, because it cannot be used as reserve, but requires additional reserve to handle It, so the emergency currency should not be put Into circulation unless actually needed. Remember that the notes and collateral to be offered for re*discount must be In tip-top shape and prepare your securities accordingly. 61 P r e ss rep orts th a t th e E x e c u tiv e C o m m ittee of th e O. B. A., or any o f its officers, fa v o r s r u sh in g th e co tto n crop o n to the m arket or op p ose co tto n w a r e h o u se p la n s, a re fa lse . T h ey favor co-operation b e tw e e n th e b a n k ers and th e fa rm ers to work out th is big problem . W e w ill b e g la d to r e c e iv e s u g g e s tions from you. Y ours tru ly , W . B. H A R R ISO N , S ecreta ry . CITY N A T IO N A L B A N K . A ltu s, O kla., D ec. 24, 1914. (2) MR. F R A N K K ELL, W ich ita F a lls, T ex a s. D ear Mr. K ell: R egardin g proposed ch a n g e o f S o u th ern O k lah om a b an k s in to K an sas C ity D istr ic t: I d eem it u n w ise a t th is tim e to m a k e a n y c h a n g e , in fa ct, w e are very w e ll p lea sed w ith D a lla s. Sh ou ld a m a jo r ity o f S outhern O klahom a b a n k ers fa v o r K a n sa s C ity, th e ch a n g e could be effected a t so m e fu tu re tim e. I tru st th a t th ere w ill b e no c h a n g e m ad e a t th is tim e . Y ours v e ry tru ly , J. T. W OOD, P r e sid e n t. T H E F IR S T N A T IO N A L B A N K . A p ach e, O kla., A ug. 31, 1914. (3) MR. OSCAR W E LL S, H ou ston, T exas. D ear Sir: I have your le tte r o f th e 29th in sta n t, r e la tiv e to th e m a t te r of m aking any ch a n g es in th e p r e sen t bou n d ary lin e s o f th e D a lla s R egion al Bank. I w ould be very glad in d eed to fa v o r you p erso n a lly in any w ay th a t I could, but w e fe e l in O k lah om a th a t our S ta te Should not be divid ed , and sin c e w e h a v e, m o s t of us, d ea lt p rincipally w ith K a n sa s C ity, w e n a tu ra lly look th a t w a y tor our banking co n n ectio n s. I lik e T e x a s and h er p eo p le, b u t I w ould have to g e t acq u a in ted dow n th ere. N a tu ra lly , w e a re In clo se touch w ith O klahom a C ity b an k ers, and th e y a re Very an xiou s to g e t th e lin e s ch a n g ed . I h a v e n o t heard la te ly o f an y a ction b ein g tak en in th e m a tter. 62 In our dealings with a Regional or Reserve Bank, I do not see that it can make very much difference whether the Bank Is located In Dallas or Kansas City; however, as stated above, our business relations with Texas points have been very limited. Our business outlook would be very good only from the fact that the cotton market is unsettled. Very truly, W. T. CLARK, President. THE FIRST NATIONAL BANK. Ardmore, Okla., Dec. 24. 1914. (4) TO THE FEDERAL RESERVE BOARD, District No. Eleven, Dallas, Texas. Dear Sirs: There has something been said about, and some protest been made against, the Southern part of Oklahoma being placed in Federal District No. Eleven, and, in connection with this matter, we desire to say, so far as we are concerned, we are absolutely satisfied as it is now. It is tree that when the Dis tricts were first designated by the Department a t Washington we signed a printed request that was circulated for that pur* pose, to have Southern Oklahoma changed, and placed in the Kansas City District But, so fa r as we now can see, we think we would be better served, and have so far been better served, by the Dallas District, than we could have been by the Kansas City District Very truly, C. L. ANDERSON Cashier. STATE NATIONAL BANK. Ardmore, Okla., Sept. 4, 1914. (8) MR. OSCAR WELLS, Houston, Texas. Dear Mr. Wells: in reply to your favor of the 28th ult., that there is ttill some work being done to trtMtema to K u tw City. Of eoone. the boy. ta the Southern Mtt ot the s u te were we understand try to have us majority ot the against dWldinc 63 Oklahoma, and preferred to have it all in th e K ansas City Dis trict. We, however, have decided to rem ain neutral, as we have very friendly relations both with K ansas City and Texas. In our case, m ost of our officers are Texans and have a large acquaintance in th a t S tate, and, naturally, we feel th a t we will be well taken care of. W ith best personal wishes, I rem ain, ; Yours very truly, HAROLD WALLACE. Cashier. THE CHICKASHA NATIONAL BANK. Chickasha, Okla., Aug. 31, 1914. (6 ) MR. OSCAR WELLS, Vlce-Pres. F irst Nat. Bank, Houston, Texas. Dear Mr. Wells: I am just in receipt of yours of 29th, relative to the Southern portion of Oklahoma making an effort to connect itself with the Federal Reserve Bank at K ansas City, instead of the Dallas District, and in reply I will say th a t I attended a meeting of the State Executive Committee of the Oklahoma Bankers Association, of which I am a member, on Saturday, August 29th, and this m atter came up for discussion before the meeting. I suggested th a t we pass the m atter over now and make no effort at all to do anything along this line, as it had already been ordered and decreed th at we were to be placed in the Dallas D istrict, and th a t I for one saw no hopes of making any changes and th a t it was far best for us to go on and make the best of the situation and la te r on. if we found that it was not convenient for us to handle our business through Dallas, th a t we could then take the m atter up w ith the Federal Reserve Board and ask for the change a t some future date, but th at at the present time I saw no hopes for any change being made in the District. I am glad to say th at my views were considered in the m atter, and it was passed over without any action being taken. In justice to Mr. Bings, of Ardmore, I will say th a t he agreed with me on this proposition, and we two were the main ones who advocated no Change being made a t this time, and I don’t think anything more will come of the proposition. Being a Texan myself, I feel very much at homo with a great many of the Texas 64 bankers, bat there is a strong fM U se ltere Cor- a With Wad personal reg a rd s and best wishes, I «un, Toors ▼err truly, T - H . D W YER, President. T H E FIRST N ATIO N AL H AN K . Chickasha, O kla., A ug. 81, 1914. (7) MR. OSCAR W ELLS, Care First National Bank, Houston. Texas. Bear Mr. W ells: I have your favor o f the 29th, advising that owing to the division made in locating Federal Reserve Banks a t Dallas and Kansas City, you have been very m o d i interested In the affairs of the Southern portion o f the State, and -in reply beg to state that wo naturally thought a ll the tim e that w e would be put In a District * whereby w e would patronise a bank located at City or S t. Louis, and w e preferred Kansas City, our mail facilities being very good, and o f course having done a large per cent o f our business a t K ansas C ity, but after learning we ha-3 been placed in the U th D istrict, w ith a Bank to be located at Dallas, we did not allow ourselves to be dis couraged, as we felt this n atter was o f m uch Importance to the whole country, and had been w ell looked into by the gen tlemen making such division, and if it developed that it was a disadvantage to the State to be divided, it could later be worked out. W e have contented ourselves on being able to transact our business satisfactorily with the Federal R eserve Bank at Dallas, and we should still be able to m aintain our business relations with Kansas City, St- Louis and other BJastern points. W e have no special objection to m ake a s to the m all facilities at Dallas, and if our securities which w e have in Oklahoma can be recognized at the Federal R eserve Bank at Dallas by the Board, we know o f no reason w hy our busi ness should not be pleasant. I appreciate very much the interest you are affairs, and hope to see you often on the Board. Yours very truly, B®N F. JOHNSON, Vice-Pres. 65 THE OKLAHOMA NATIONAL BANK. C hickasha, Okla., Aug. 31, 1914. (8) MR. OSCAR W ELLS, F irst N ational Bank, H ouston, T exas. Dear Mr. W ells: R eplying to yours of A ugust 29th, w h ile to begin w ith, it w as the opinion o f our bank, con sid erin g th e trend of b u sin ess in this section , th at it w ould be b e st for us to be in the R egional Bank D istrict w ith K ansas City or St L ouis, how ever, sin ce the boundaries w ere fixed different and not know ing Just w hat would be b est for us, w e have never joined in any m ove looking to a change, and don’t think w e sh all u n til after we have tried out the proposition and realize w h a t is b est for us. Som e of our Oklahom a banker friends h ave criticised us severely for the stand w e have taken. A nyw ay, th eir view s have not changed our plans. Thanking you for your letter, and hoping it m ay be proven it is b est for us to be coupled up w ith the D allas R eserve Bank and th at all of us m ay se e lo ts of b en efits under th e new schem e, I am, w ith p ersonal regards, Y ours very truly, R. K. W OOTTEN, RKW-BH P resid en t. THE OKLAHOMA STA TE NATIONAL BANK. Clinton, Okla., Jan. 16, 1915. (9) FEDERAL RESERVE BOARD, W ashington, D. C. Gentlemen: In the m atter of change in the boundary lin e b etw een 10th and 11th Federal R eserve D istricts, the h earing of w hich is soon to com e up before your Board, it m ight be w ise to p o st pone your decision until th e different R egional B anks get in to full w orking order in all its fu n ction s, and th en it could be readily ascertained to w hich D istrict the questioned territory belongs. If the discount ra tes are kept som ew h ere near equal, it m atters but little to w hich D istrict any o f us belon g, until 00 th e fu n ctio n s o f th e C le a rin g H o u s e a r e p u t I n to o p e ra tio n , and th en som e re -a d ju s tin g w ill m o s t l ik e l y b e In o rd e r. Y o u r s t r u ly , C. W . BREW ER, P re sid e n t. T H E F I R S T N A T IO N A L B A N K . C o m a n c h e , O k la ., D e c. 26, 1914. (10) FE D E R A L R E S E R V E B O A R D , W ashington, D. C. G entlem en: Som e tim e a g o w e e x p r e s s e d o u r p r e f e r e n c e to b e in th e K a n sa s C ity D is tric t, b u t s i n c e t h e y h a v e b e g u n o p e ra tio n s and w e h a v e th o u g h t t h e m a t t e r o v e r , w ill s a y t h a t i t w o u ld be ag reeab le to u s to r e m a in i n t h e D a l la s F e d e r a l R e s e rv e D istrict. V e ry tru ly , R. M. RALLS, P r e s id e n t. T H E F I R S T N A T IO N A L B A N K . E l k C ity , O k la ., D e c . 24, 1914. (11) MR. FR A N K K E L L , D ir e c to r , F e d e ral R e se rv e B a n k , D allas, T e x a s. D ear Mr. K e ll: In re g a rd to m a k in g a n y c h a n g e s o f t h e b o u n d a r y lin e s of th e F e d e ra l R e s e rv e B a n k s : I n m y o p i n io n i t w o u ld b e best to w a it u n til t h e F e d e r a l R e s e r v e B a n k s a r e i n g o o d r u n ning order. W e would p re fe r b e in g i n t h e K a n s a s C i ty D i s t r i c t , b u t w e a re w illing to w a it u n t il t h e B o a r d o f D i r e c t o r s o f t h e F e d eral R eserve B a n k h a v e t h e i r b a n k s i n g o o d r u n n i n g o r d e r , a s to m ake an y c h a n g e s n o w m i g h t c a u s e s o m e c o m p l i c a ti o n s an d we would w a n t to r e s e r v e o u r r i g h t o f t r y i n g t o g e t c h a n g e d a s soon a s th e R e se rv e B a n k s g o t i n g o o d r u n n i n g o r d e r an d w here it w ould n o t c a u s e m y c o m p l i c a ti o n . Very truly yours, A. L. THURMOND, AWAH Cashier. 6T AMERICAN NATIONAL BANK. Holdenville, Okla., Aug. 31, 1914. ( 12) MR. OSCAR WELLS, Vice President, First National Bank, Houston, Texas. D ear Sir: In reply to your letter of August 29th, will say that, as fa r a s I am concerned now, I had just as soon be in the D allas District as in the Kansas City District, for the reason th a t I think the Dallas District will understand this cotton condition better than any other. I think the Dallas District w ill fully realize what we are up against in this cotton sec tio n , an d will understand how to handle the situation better th a n if we were in a grain or any other territory. Therefore, I am perfectly content to remain in the Dallas District. Yours very truly, L. T. SAMMONS. President. NATIONAL BANK OF COMMERCE. Hollis, Okla., Jan. 5. 1915. (13) THE FEDERAL RESERVE BOARD, W ashington, D. C. G entlem en: H aving had a conversation with Mr. Frank Kell, of Wichita F a lls, T exas, who is a member of the Board of the 11th Dis tric t, reg ard in g the contemplated change from the 11th to the 10th F e d e ral District of the Southern part of Oklahoma. 1 w ish to say that it seems to me that the first thing we should do is to lend all of our energies toward the perfection of the F ed eral B ank plan. W e a re in the 11th District, and as yet I have been unable to decide a s to which District it would be most to our interest to be perm anently placed in. We have a direct railroad connec tio n w ith Dallas and, from the standpoint of convenience it seems th a t D allas would be o u r preference. Of course, there is a possibility that the financial interest o f th e State of Oklahoma might be injured should the bound a ry lines remain as they now are. but as it has not been tried out, and the entire plan is an experiment, I hardly believe th a t th e matter could be intelligently settled at this time. Respectfully. CWO-M O. W. GILLILAND. P re sid e n t 68 T H E S T A T E N A T IO N A L B A N K O P H O L L IS . H o llis , O k la ., J a n . 15, 1915 (14) FE D E R A L R E S E R V E B O A RD , W ash in g to n , D. C. G entlem en: In re g a rd to th e p ro p o se d c h a n g e in t h i s R e s e r v e D istrict, we p re fe r to s ta y in th e D a lla s D is tr ic t, o n a c c o u n t o f the d istan c e an d c o n n e c tio n s w h ic h t h e m a lls m a k e . W e a r e only tw elve h o u rs fro m D a lla s a n d a b o u t fo r ty - e ig h t h o u r s from K a n sa s City. Y o u rs r e s p e c tf u lly , W . S. C R O S S , P re s id e n t. T H E F IR S T N A T IO N A L B A N K . M a n g u m , O k la ., A u g . 31, 1914. (15) MR. OSCAR WELLS, H ouston, T ex a s. Dear Mr. W ells: I am v e ry g la d to h a v e y o u r l e t t e r r e g a r d i n g t h e m o v e on p a rt of th e O k la h o m a b a n k e r s t o b e t r a n s f e r r e d t o K a n s a s City D istrict. P e rso n a lly , w e w o u ld p r e f e r t o r e m a i n as w e a r e , i n y o u r D istrict. H o w ev er, t h is i s o n s e c o n d j u d g m e n t , as w e p r e f e r r e d K a n sas C ity a t first, a n d w h e n t h e r e m o n s t r a n c e w a s f ir s t m ade, w e jo in e d in t h is , b u t s in c e t h e n w e w ill s t a n d p a t on D allas. I w a n t to c o n g ra tu la te y o u o n b e in g s e l e c t e d o n t h e B o a rd , and w e fe e l t h a t t h e e n ti r e D i s t r i c t w ill b e b e n e f i te d b y h a v in g you a s a D ire cto r. W ith k in d e s t p e rs o n a l r e g a r d s , Y o u rs v e r y t r u l y , H . M A TH EW SO N, P re s id e n t. T H E F IR S T N A T IO N A L B A N K . M a r i e t t a , O k la ., A u g . 27, 1914. (16) MR. BEN 0 . SM IT H , P r e s id e n t, F. & M. N a tio n a l B a n k , F o rt W o rth , T e x a s, D ear S m ith : 1 am duly in receipt of your favor of the 24th Inst., and 69 note w h a t you sa y a b o u t i t having been brought to your a tte n tio n t h a t th e re m ig h t s till e x ist som e opposition to the S o u th e rn p a r t of O klahom a bein g included in th e Eleventh R eg io n al B a n k D istric t, a n d d e sirin g to know from me, in my Opinion, w h a t th is opposition, if any, w ill am ount to or exert with th e W ash in g to n D ep artm en t. In re p ly w ill say , a s f a r a s m y personal view s a re conoerned, w h e n I firs t le a rn e d th a t th e Southern p a rt of Okla homa w a s to b e included in th e D allas D istrict, instead of K a n sa s C ity, I th o u g h t i t w as a m ista k e and th a t it would have b e en b e tte r if w e h a d been placed in th e K ansas City D istrict. H ow ever, sin c e th e n , an d a fte r thin k in g th e m atter over m o re c are fu lly , I am fra n k to say, th a t while from one sta n d p o in t i t looks lik e i t would be b e tte r for th e S ta te of O klahom a to a ll b e in one D istrict, from a financial standpoint and th e f u r th e r fa c t o f D allas b eing very centrally located as a c o tto n p o in t a n d in a se n se h aving a g re a t deal m ore tra n s a c tio n s a n d b u sin e ss w ith b a n k s in th e cotton section th a n K a n sa s C ity, i t a p p e a rs to m e, a s you say, th a t the D allas R egional B a n k should b e m ore com petent and possibly have m o re e x p erien c e in th e h an d lin g of cotton th a n th e K ansas City B a n k w ould. On th is account, I am very m uch in favor of th e D istric t bein g le ft alone an d th e Southern p art of O klahom a re m a in in g in th e D allas D istrict. * * * * H oping, how ever, t h a t th is opposition m ay not am ount to much an d t h a t th e re w ill n o th in g com e of it, and th e D istrict remain u n ch an g ed , a n d fu rth e r, th a t I have m ade m yself dear, a s to how I s ta n d personally, w ith reg ard to sam e, w ith ' k in d e s t re g a rd s a n d b e s t w ishes, I rem ain. Y ours very truly, P. B. COXRAD. President. T H E F IR S T NA TIO NAL BANK OF MARLOW. M arlow, Okla., Aug. 29. 1914. (17) BEN O. SM ITH , P re sid e n t, F . & M. N atio n al B ank, F o rt W orth, T exas. Daar Mr. Smith: In m y opinion, th e re is n o t m uch opposition to being in With T ex a s am ong th e sm all banks, o r a t least nothing like there w as a t first. A nyw ay, th e re is no ag itation of it. Most Of us h a v e com e to th e conclusion th a t it m akes no difference 70 where we are. So m any m u ch g r e a te r a n d m o re g ra v e m atters a re coming up th a t I d o u b t if a n y th in g is t r ie d t h a t w ill change the D istrict lines. Today’s p ap ers sa y t h a t a m e e tin g o f b a n k e r s is on in Oklahoma City, b u t I had h e a rd n o th in g o f it, a lth o u g h I am reported to be th ere . A few p e o p le w o u ld lik e to h a v e the change m ade, b u t th ey a re n o t g e ttin g u p m u c h e n th u s ia s m . W ith th e b e st of re g a rd s, a n d h o p in g to h a v e m o re bu si ness some of th ese days fo r you, Y o u rs v e ry t r u ly , T. L. W ADE, C ash ier. THE ST A T E N A T IO N A L B A N K . M arlow , O k la ., J a n . 9, 1915. ( 18) FEDERAL RESERV E BOARD, W ashington, D. C. Gentlemen: Some m onths ago, w hen we w e re a d v is e d t h a t w e w e r e t o be placed in th e D allas D istric t (No. 11), w e, a lo n g w ith o th e rs from this country, e n te red o u r p r o te s t, a s m o s t o f o u r b u s in e s s had been In K ansas City an d St. L ouis. After further consid eratio n of th e m a tte r , w e d e s ir e t o s a y th at we will, for the p re se n t, w ith d ra w o u r p r o t e s t a n d w ill be satisfied to rem ain in th e D a lla s D is tr ic t u n t il t h e s y s te m has been given a thorough tria l, a n d u n til s u c h t im e a s w e ascertain from experience w h e th e r o r n o t, in o u r ju d g m e n t, i t would be b e tte r for u s to be in th e K a n s a s C ity D is tr ic t. R e sp e c tfu lly , O. R. M CK IN N EY , C a sh ie r. TH E FIR ST N A TIO N A L B A N K . P o te a u , O k la., J a n . 12, 1915. (1») MS. B. A. McKINNEY, Federal Reserve Bank, Dallas, Texas. Dear Buck: In these days of agitation, financial a n d o th e rw is e , I a m becoming convinced th a t to “L e t w e ll e n o u g h a lo n e " is a good axiom. The strenuous effort to effect a ch an g e in F e d e r a l R e s e rv e District No. 11, adding O klahom a t o th e K a n s a s C ity D is- 71 trlo t, se e m e d to m e to b e a p ro p e r procedure and for the 'b e s t I n te re s t o f a ll o f w e O klahom a bankers who petitioned; a n d , n o t to b e c o n tra ry , I sig n e d th e petition for this bank, Mfce a m a jo rity . S in c e th e m a tte r will soon be heard by the "Federal R e se rv e B oard, I have given th e question of changing, m o re th o u g h t t h a n h e re to fo re —a t least m ore intelligent thought —fo r th e reason t h a t I now know m ore about th e Federal R e se rv e B a n k s a n d th e ir functions th an heretofore, and I im ag in e th is is tr u e o f th e m ost of th e bankers. T a k e th e in d iv id u a l c a s e of th is bank. A fter summing Jt a ll up, I find o u r m a il se rv ic e to Dallas is a few hours shorter th a n In to K a n sa s C ity. T h e SERVICE of one Federal Reserve B a n k a p p e a rs to b e a b o u t th e sam e as th e other. So far as I know , th e d isc o u n t r a te s are th e same. Item s for credit a n d b a la n c e s to c h ec k a g a in s t seem ingly are ju s t as convenient fo r u s a s th e y w ould b e in K ansas City or St. Louis. A few w e e k s’ o p e ra tio n o f th e b a n k s h as changed my ideas con c e rn in g th em . I do n o t w a n t to b e p u t in th e position of going back o n th e p e titio n I sig n e d along w ith the oth er Oklahoma b a n k e rs, b u t th o u g h t would drop you a line to say th a t sin ce finding o u t m o re a b o u t th e modus operandi of Federal R e se rv e B an k s, t h a t i t m akes do difference to me if the Dis tr ic t re m a in s lik e it is. In fact, I believe I prefer it now, a s i t is. I h a v e fe lt t h a t th e strong effort being put forth to ch an g e th e b o u n d a ry lines would n aturally cause you to take a k e en in te r e s t in th e m a tte r from a personal standpoint, and I w a n ted , in th is le tte r, to express my “honest convictions" t h a t p e rh a p s a lo t o f u s h a d rushed into som ething th a t we re a lly d id n ’t know w h e th e r we w anted it or not. W ith th e k in d e s t of regards, I rem ain, Cordially and sincerely yours, TOM WALL. Cashier. T H E FA R M E R S AND MERCHANTS NATIONAL BANK. Roff, Okla., Aug. 25. 1914. (20) R E SE R V E B A N K ORGANIZATION COMMITTEE. W ash in g to n , D. C. S irs: W e u n d e rsta n d th a t th e re is a m ove on foot to place the Bfitlre S ta te o f O klahom a in th e K ansas City R eserve District. I f th e D a lla s D istric t will be as able to take care of 72 our needs for funds as the Kansas City District, we prefer that the Districts be left as they are, for the reason that we are a cotton growing section and our needs are identical with most of the banks of the Dallas District. We are not in favor of any move that will delay the com* pletJon of the organization of the Reserve Banks. Yours very truly, FARMERS & MERCHANTS NATIONAL BANK, By J. A. GILBERT, Cashier. (21) Tishomingo, Okla., Dec. 19, 1914. TO THE HONORABLE FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: The undersigned banks of Johnston County, Oklahoma, hereby petition your Honorable Board to make no change In the line* of the Federal Reserve District as established by the Organization Committee, and we express ourselves as satisfied with the lines as they now exist. If in the event the lines should be disturbed in any man ner, we ask that at least Johnston County be permitted to remain in the Dallas District. Respectfully yours, THE TISHOMINGO NATIONAL BANK, L. L. CALDWELL, Cashier. FIRST NATIONAL BANK, Wapanucka, Okla. R. E. WADE, President. FIRST NATIONAL BANK, Milburn, Okla. J. W. WALKER, Cashier. ‘FARMERS NATIONAL BANK, Tishomingo, Okla. C. B. BURROWS, President. THE FIRST NATIONAL BANK. Wapanucka, Okla., Dec. 22, 1914. h r . b . a. (32) McKin n e y , Durant, Okla. Dear Sir: Your letter bearing date of the 19th Inst, received, and in reply will say that we are perfectly satisfied in the Dis trict No. 11, slid will bo glad to sign the petition to stay in TS th e D a lla s D is tric t, a n d b e glad to do a ll w e c an to r you. I re m a in , Y ours v e ry tru ly , R. E . W ADE, P re sid e n t. EXHIBIT B. T H E OK LA HOM A B A N K E R S ASSOCIATION. Office of th e S e c retary . O klahom a C ity, A pril 7, 1914. (1) TO O. B. A. M E M B E R S IN DALLAS D ISTR IC T. G e n tle m en : W ith o u t p re su m in g in th e le a s t to d ic ta te in th e m a tte r of th e re g io n a l re s e rv e b a n k D istric ts, w e fe el th a t a n o th e r l e tte r a t th is tim e w ill be w elcom ed by you, In view of th e m an y u rg e n t le tte r s a n d te le g ra m s w e h a v e received. T h e w r ite r h a s m uch in fo rm a tio n w hich i t is im possible to convey in a le tte r, b u t th e m ain p o in t is : A fte r com m u n ic a tin g w ith S e n a to rs Ow en an d Gore, a ll O klahom a’s C ongress m en, a n d a f te r c o n su ltin g w ith b a n k e rs in K a n sa s City per so n a lly a n d c a n v a ssin g th e situ a tio n a s tho ro u g h ly a s tim e has p e rm itte d , w e a r e convinced th a t th e re is a re aso n a b le chance, b y p ro p e r a c tiv ity , to g e t O klahom a placed in one regional d istric t. A s fo r a b ra n c h b a n k , th e a d m in istra tio n forces a re in clined to a d o p t th e policy of placing b ra n ch e s only w here th e re a re n o t o v e rn ig h t fa c ilitie s fo r h an d lin g business. U nder t h a t policy, a n d th e D istric ts as now fram ed, every city in O klahom a is b a rre d fro m o b tain in g a bran ch . O ur In fo rm atio n is, t h a t 95<^, o f th e O klahom a banks th a t h a v e b e e n p lac ed in th e D allas D istric t a re very m uch opposed to th is a rra n g e m e n t. W e a s k th a t a n y b a n k th a t is C ontented to re m a in in th a t D istrict, p lea se w rite u s a t once. A ll o th e rs sh o u ld fill o u t th e enclosed form AND R ETU R N TO T H E W R IT E R (Do n o t m ail it to W a sh in g to n >. T h is is VERY IM PO R T A N T AND SH O U LD H A V E YOUR IM M EDIATE AT T E N T IO N . F u r th e r su g g e stio n s will follow developm ents. V ery tru ly yours. W . B. HARRISON. S e c retary O. B. A. 74 THE OKLAHOMA BANKERS ASSOCIATION. Office of the Secretary. Oklahoma City, Okla., April 13 , 19l, (2) TO THE BANK ADDRESSED: We have not as yet received from you one of the signed slips like the enclosed which w e m ailed you a w eek ago and asked to be returned im m ediately. T h is is exceedingly important, and we cannot put too much str e ss on th e necessity of hearing from every Oklahoma bank in th e D allas District at once definitely. If you want to be in th e D allas District, please state that plainly. If you do not, sign th is slip today, and mail to us, unless you already have on e in th e mail. We admit that there is only a fighting ch an ce to get the District changed, but we have good reason to b eliev e it can be done. Today we have received from W ashington a signed statement by a high government official, w h ose support means as much to us as that of any other man, sayin g he thinks this change can be made if the banks w ill a ll sig n th e protest. It is very important to not only send th is in, but to wire your Congressman and Senators, unless you h a v e already done so. Let them hear from you direct in p rotest a g a in st the lines as at present formed, if you feel that w ay about it. W e have received 220 replies to date, of which 215 h a v e been pro test. Remember we are working day and n ig h t on th is propo sition in your interest and intend to keep up th at work until we get a decision. So please do your part by forwarding the slip to us by next mail. Yours truly, W . B. HARRISON, Secretary 0 . B. A. EXHIBIT 0. THE FIRST NATIONAL BANK. Altus, Okla., Dec. 24, 1914. ( 1) MR. PRANK KELL, Director of the Federal Reserve Bank, 11th District, Dallas, Texas. Dear Sir: In my opinion it would be unwise to m ake any change of the line of Southern Oklahoma from this D istrict, especially 75 j u s t now . T r u s t y o u r B o a rd w ill c o n sid e r th e m a tte r care fu lly a n d d e cid e n o t to m a k e a n y ch an g e . Y o u rs v e ry tru ly , J . A. H EN RY , President. ; T H E F IR S T N A T IO N A L BANK. B ro k e n Bow, O kla., Aug. 14, 1914. ( 2) HON. B. A. M cK IN N E Y , D u ra n t, O kla. D e a r S ir: W e d e sire to c o n g ra tu la te you upon y o u r election a s a D ire c to r o f th e F e d e ra l R e se rv e B a n k o f th is D istric t, and to c o n g ra tu la te th e D is tric t u p o n its w ise selectio n , w hich is e n tire ly in a c c o rd w ith o u r ow n p e rso n a l w ishes. W e a r e now re a d y to giv e o u r h e a rtie s t su p p o rt tow ards re ta in in g th e S o u th e rn p a r t o f O klahom a in th e D allas D is tric t, a s i t is n o w divided. W e w ill oppose any plan s w hich m a y b e p re s e n te d to in c lu d e u s in th e K a n sa s City D istrict, a n d if th e r e is a n y w a y in w h ich w e m ay be of a ssista n c e in th is m a tte r, k in d ly le t u s know . W e a r e sa tis fie d w ith o u r D ire cto rs, an d w ith th e Dis t r ic t a s i t s ta n d s . Y ours v e ry tru ly , F. L. MALLORY. (S e a l) Cashier. T H E F IR S T N A TIO NAL BANK. Coalgate, Okla.. 8*24*14. (3) F E D E R A L R E S E R V E BOARD, W ash in g to n , D. C. G en tlem en : W e h a v e been inform ed re c e n tly th a t th e re is a move m e n t on foot to tra n s f e r th e b an k s in Southern Oklahom a now In th e E le v e n th D istric t, h e a d q u a rte rs a t D allas, Texas. S p e a k in g fo r o u rse lv es, a s well a s fo r m any o th e r bankers in th is se c tio n o f th e S ta te , w e m uch p re fe r being in the D a lla s D istric t th a n th a t of K a n sa s City, and would regret v e ry m uch to be tra n sfe rre d . H oping th a t you m ay se e m a tte rs a s we do in regard to th is m a tte r, w e rem ain, Very respectfully. R. P. CAR SO N . RPC-M KH Vice-Pro*. 76 THE FIRST NATIONAL BANK. Frederick, Okla., Jan. 8, 1915 (4) FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: It appears that an effort is being made by certain Oklahoma bankers to change the boundaries of this District, and that they have presented a petition to your Board, asking that all of Oklahoma except a few Southern Counties be trans ferred to the Kansas City District. It is my opinion that this movement was instigated by Oklahoma City bankers, and is being pushed on account of in* terests of Oklahoma City parties, and not for the welfare of a majority of bankers in the District. We are highly pleased with the selection of Dallas as the reserve center of this District, and hope that no change will be made in the present District lines. Yours very truly, J. B. BEARD, Jr. Cashier. THE NATIONAL BANK OF COMMERCE. Frederick, Okla., Sept. 1, 1914. ( 5) MR. OSCAR WELLS, V. P. First National Bank, Houston, Texas. Dear Mr. Wells: Your letter of the 29th ult. is just received, and I wish to say, in reply, that I have been one of the few in Southern Oklahoma who have been entirely content with the arrange ment of the District. It appears to me that the arrangement was perfected after a comprehensive and a thorough examination into the claims of all parties concerned, and by a committee which had a much better opportunity to weigh matters with justice. I feel altogether inclined to remain in the Dallas Dis trict, and in fact am glad that we are placed there. I am glad you wrote me about the matter, and with kind per sonal regards, I am, Y o u rs tr u ly , C W H -M M C C. W . HO W A RD . Pres. 77 T H E F IR S T N A T I O N A L B A N K . G r a n d fie ld , Okla. A p r. 4 (6 ) 1‘ili CITY NATIONAL BANK, D allas, T exas. G entlem en: W e w ish to c o n g ratu late you and your city upon t h e securing of th e location for one of th e Regional Reserve B anks. And we a re indeed glad to be located in a D istrict with th e c e n tral city so close to our doors. W e th a n k you for th e services tendered in connection with handling b u sin ess th ro u g h th e R eserve Bank, and when the opportune tim e a rriv e s for opening an account in Dallas, we sh all rem em b er your good bank. Yours respectfully, O. E. M A P E L , Cashier. THE F I R S T N A T IO N A L K io w a , BANK. O k la ., A u g . 14, 1914. (7 ) FED ER A L R ESE R V E BOARD, W ashington, D . C. G entlem en: R eferring to th e e ffo r t o f O k la h o m a C ity to c h a n g e th a t p a rt of O k la h o m a t h a t is in F e d e r a l R e s e r v e D is t r ic t E le v e n , from th e D a lla s to t h e K a n s a s C ity D is t r ic t, w e a r e p le a s e d w ith th e D is t r ic t a s m a d e , a n d f e e l th a t th e b u s in e s s o f S outhern O k la h o m a c a n b e b e s t h a n d le d th r o u g h th e D a lla s D istrict, and desire to p r o t e s t a g a in s t t h is c h a n g e b e in g m a d e. Y ours (Seal) T H E L E H IG H R e s p e c t., C. W . C R U M , C a sh ier. N A T IO N A L B A N K . L e h ig h , O k la., J u n e 11, 1914. (8 and 9) TO T H E F E D E R A L R E S E R V E B O A R D , W ashington, D . C. * We, th e u n d e r s ig n e d b a n k s , o f L e h ig h , O k la h o m a , h er ®by p ro test ag ain st a n y c h a n g e b e in g m a d e to w a rd re-d istric t ng th e S outhern p a rt o f O k la h o m a , w h ic h is lo c a te d in th e n u R eserve D istrict. 78 The undersigned banks are satisfied with Dallas for the reason that we have daily connections with this city, whereby we believe that it will be to our best interest to be associated with this bank. Further, we do not believe that the Reserve Board will allow any discrimination in the interest rates, owing to the strong demand for assistance during the marketing of our cotton crop, which the entire 11th District is called upon to finance at the same time. Assuring you of any assistance or information that we have, at any time called upon, we are, Very truly yours, THE LEHIGH NATIONAL BANK, Lehigh, Okla. TOM MITCHAM, Cashier. THE MERCHANTS NATIONAL BANK, Lehigh, Okla. OLLIE L. BEARD, Cashier. THE FIRST NATIONAL BANK. Milbum, Okla., June 6, 1914. 10 ( ) TO THE FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: We feel it our duty to say a few words in behalf of the Reserve Board in locating the District line as they did through the State of Oklahoma. Inasmuch as the Southern part of the State is devoted to cotton growing, as well as the balance of the Eleventh District. We believe it would also be to the best interest of all concerned should we have a Board of Directors coming from Texas, the Southern part of New Mexico, and the Western part of Louisiana, rather than one coming from Colorado, Wyoming, Nebraska, and those other States that know nothing about the problems of a bank charged with the duty of financing a cotton crop. It appears to us that the Federal Board has acted wisely in placing us in the Eleventh District, with Dallas as a reservo center. We therefore commend them. Yours very truly, C. B. CARTER, (Seal; Asst. Cashier. 79 THE FIRST NATIONAL BANK OP ROFF. Roff, Okla., Aug. 21, 1914. (ii) FEDERAL RESERVE BOARD, Washington, D. C. Sirs: There is a movement on foot among some of the bankers of Oklahoma to try to have all of Oklahoma placed in the Kansas City Federal Reserve District. We understand that a delegation is already on the way to Washington for that purpose. We feel th at there are a great many of the bankers of Southern Oklahoma who feel as we do about the matter: We would much prefer that the arrangement be left just as it is. The interests of Southern Oklahoma are identical with those of Texas and the other cotton States. We are strictly a cotton country, and what would serve Texas the best would also be best for us. On the other hand, were we to be placed with Kansas City, we would only be a very small cotton producing community, placed with a large country, where practically nothing is known about cotton, or the handling of it. Dallas is much easier to reach from this section by mail or telephone, and we feel th at practically everything is in favor of Dallas, oyer Kansas City, as far as Southern Oklahoma is concerned. We are sure that in considering this proposed change, both sides of the question will be fully considered, and we feel th a t you will decide to let the Districts remain as they are. No doubt, there will be more agitation for a change than there is against a change, as there are a great m a n y more banks in Oklahoma who are in the Kansas City District, than a re in the Dallas District, but we have discussed the matter with a great many of the bankers of Southern Oklahoma, and we believe a great majority favor remaining in the Dallas District. Very respectfully, H. HUGHES, Cashier. THE FIRST NATIONAL BANK. Ryan, Okla.. Jan. 7, 1915. (13) MR. OSCAR WELLS, Governor. Federal Reserve Bank, of Dallas. Dear Sir: While there is being made strong efforts to re-dfotrlct our section of Oklahoma by a few of our members, we feel 81 others are with St. Louis, Chicago, Kansas City, Fort Smith, Little Rock or various other centers. You will find on investigation that the reasons given by these banks protesting against Southern Oklahoma being placed with Dallas for wanting the District changed, will vanish as soon as the Federal Reserve system is put in actual operation. The Oklahoma City banks sent out the protests all ready to be signed up by the different banks and urged that every bank join in the protest. I thoroughly believe that it is unwise to make any change in our District at this time, and that time will prove the wis dom of the Organization Committee in dividing Oklahoma along the line of its natural line of division. Respectfully submitted, L . L. C A LD W ELL, C a s h ie r . WAURIKA NATIONAL BANK. Waurika, Okla., Sept. 1, 1914. <u> OSCAR WELLS, Houston, Texas. Dear Sir: Replying to yours of 29th ult.: Our judgment has been all the while to keep every interest together as much so as possible. We think the Southern part of Oklahoma should be kept in the 11th District, that being the cotton producing part of the State. Those of us who hale from the South seem, and the cotton country seem, to be ot that opinion; but, when you find a banker from the North, who is not acquainted with the cotton business, as we are, and they want out and go to Kansas City or St. Louis. We think it a grave mistake to transfer us to one ot those Districts. We think we would be lost sight of in the mixup ot the commercial and cattle interest. Of course, there is argument pro and con, BUT LET US STAY WHERE WE ARE. Yours very truly, WADE ATKINS. President. 82 EXHIBIT D. SAM I. H Y N D S & CO. C otton M e rc h a n ts. D u ra n t, O k la., MR. B. A. M cK IN N EY , C a sh ier, D u ra n t N a tio n a l B ank, D ec. 19, 1914. Durant, Okla. D ear S ir: W e beg to a d v ise t h a t a ll c o tto n p ro d u c e d in O k la h o m a an d sold fo r e x p o rt to fo re ig n c o u n trie s , is s h ip p e d fro m O klahom a v ia G alv esto n o r N e w O rle a n s, a n d in o u r o p in io n fu lly seventy-five p e r c e n t of O k la h o m a c o tto n so ld to N e w England or C an ad ian m ills, is a ls o s h ip p e d v ia G a lv e s to n o r New O rlean s, a n d p ra c tic a lly a ll c o tto n p ro d u c e d s o u th o f t h e C an ad ian R iv er o r R o c k Is la n d R a ilro a d , is s h ip p e d v ia G a l' veston, th e n c e by w a te r to N e w E n g la n d o r C a n a d ia n p o in ts , a s th e c o m b in atio n of r a il a n d w a te r r a te s v ia t h e G u lf is l e s s th a n th e a ll ra il r a te s fro m S o u th e rn O k la h o m a . W e a lso beg to p o in t o u t t h a t f a rm e r s a n d m e r c h a n t s w ho sh ip c o tto n on c o n sig n m e n t, fo rw a rd s a m e to H o u s to n , G alveston o r N ew O rle a n s ; in o th e r w o rd s , a lm o s t t h e e n ti r e O k lah o m a c o tto n c ro p i s sh ip p e d v ia t h e G ulf. Y o u rs v e ry tr u ly , SIH-M SA M I. H Y N D S & CO. EX H IBIT E. K EM P & KELL. W ic h ita F a lls , T ex ., D ec. 21, 1914. MR. B. A. M cK IN N E Y , D u ra n t, O kla. My d e a r M r. M c K in n e y : I h a v e y o u r f a v o r o f 19th in s t. T h e m o v e m e n t o f t h e w h e a t c ro p fro m t h a t p a r t o f O k la h o m a in c lu d e d in t h e 1 1 th R e g io n a l D is tr ic t, is n e a r ly e x clu siv ely to t h e s o u th , e i t h e r th r o u g h G a lv e s to n a n d N ew O rle a n s fo r e x p o rt o r t o T e x a s f o r lo c a l c o n su m p tio n . In th e te r r ito ry a b o v e n a m e d , t h e r e i s p ro b a b ly a la r g e r p e r c e n t o f th e g ra in m o v ed t o T e x a s f o r lo c a l c o n su m p tio n b y re a s o n o f th e f a c t t h a t t h e a d ju s tm e n t of r a te s fro m ih is te r r ito ry is m o re fa v o ra b le to a T e x a s d e s tin a tio n on a d o m e stic b a sis th a n to a n y o th e r p o in t fo r con* s u m p tio n , e ith e r fo r d o m e stic o r e x p o rt u se . M o st o f th e w h e a t g ro w n in th is te r r ito ry a b o v e o u tlin e d i s g ro w n in th e S o u th w e ste rn p a r t o f th e S ta te o f O k la h o m a , w h e re th e c o m m e rc ia l affiliation is la rg e ly w ith T e x a s con- 83 nections, and I might say, almost exclusively with Texas connections, so tar as the grain business is concerned. The surplus oats grown In the State of Oklahoma embraced in the 11th District, is very largely consumed in the South east, either in Arkansas and Louisiana, or beyond the river, through the Memphis gateway. Some of this comes to Texas, and is consumed in a local way, when the Texas crop is short; but most of the crop in the territory above named goes to the Southeast. The surplus com of this part of Oklahoma is nearly all moved to Texas or to Galveston and New Orleans for ex port. Seldom does the surplus corn of that section move in any other direction. Now and then you will find seasons when, for a short while, it will move through the Memphis gateway. This lasting only until such time as the Kansas corn may com mence to move freely. I feel quite sure that so far as the surplus grain grown in the territory above named is concerned, th at 80 or 90 per cent of it moves to the South and Southeast, either for local consumption in that territory, or for export through Galves ton and New Orleans. I do not think that the opening of the Panama Canal will increase or in any wise affect the movement of grain from this territory for export, as the Pacific coast is well supplied with grain grown west of the mountains. Now and then we may have a shipment of oats to go to the Pacific coast, during years when the crop of this cereal is short in th at country. Later, we may be able to increase our volume of flour moving out through the Gulf ports for export by extending our trade to the west coast of South America, and probably the Phillippine Islands and Japan. This, however, is Quite remote and in a measure quite doubtful. There is no doubt that the imports through Galveston and New Orleans, induced by the opening of the Panama Canal, will largely increase the volume of tonnage destined to Southern Oklahoma, as the rate from the Pacific coast, through the canal to the entry ports of New Orleans and Galveston, plus the rail rate from New Orleans and Galveston to final destina tion will be lower than the all rail rate across the continent. In deed, the canned goods shipments have already commenced to move in this direction. X shall be pleased to have yonr further inquiries at any tim e th at you think I can be ot service to you. W ith kindest regards, 1 am, Yours truly* FRANK KELL. 84 E X H IBIT f. THE FIRST NATIONAL BANK. Achille, Okla., June 12, 1914. (1) FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: Inasmuch as the banks in the Northern part of Okla homa are making a strong fight to hare all of the State of Oklahoma placed in Reserve District Ten, I wish to state how the Directors of this Bank feel about the situation. We realize that the Southern part of Oklahoma is a cot ton growing country and that we have practically the same crops and conditions that the people of Texas have to con tend with. The business trend of this part of Oklahoma is towards Dallas, and we feel that we ought to have our banking facili ties in the same part of the country that our other business 1b centered. We are of the opinion that the Directors of the Federal Reserve Bank that is to be located at Dallas, in Reserve Dis trict Eleven, will better understand the conditions that we have to contend with and therefore will be in a better posi tion to take care of the needs of the banks located In the Southern part of Oklahoma. We want to file a protest against any change that may be made in the lines of the Reserve Districts that would . place this part of the State in Reserve District Ten. We feel that we properly belong to District Eleven, and we hope that no change will be made. Respectfully, W. G. COTNER, (Seal) Cashier. THE FARMERS AND MERCHANTS NATIONAL BANK. Achille, Oklahoma, June 10,1914. (2) THE FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: The proposition to revise the findings of the Organization Committee in locating Southern Oklahoma in Federal Reserve District No. 11, Dallas, Texas, is very objectionable to this section of the country, and, on behalf of this baak, 1 85 earnestly protest against any change being made from the original decision. Our interests and those of Texas are closely merged, and I mtg*1* say, identical. The character of the soil is practically the same, our crops are of the same character, and the princi pal markets for our cotton crop, give us exchange .on Dallas, Houston, Galveston and New Orleans in payment thereof, and a t the same time afford us a better price, because of the shorter haul to destination. Our corn and other small grain crops find, a ready market in those sections of Texas where the agricultural conditions make other crops more profitable, in consequence of which, very little corn and oats are raised. Since this town was established, our trade relations with Texas points have steadily increased, and I feel th a t it is to our best interests that we remain a member of Federal Reserve District No. 11. It is probably true th at the majority of Oklahoma banks maintain their reserves in City, St. Louis and New York, but this is no doubt due to the fact that these connections were established before reserve cities were designated in Texas, and it is convenient to draw E astern exchange in payment of the purchases of our m erchants from Eastern and Northern cities. Altogether, I believe th a t the Organization Committee acted very wisely in embracing South ern Oklahoma in the Dallas Reserve District, and I sincerely tru st that no change will be made from the original desig nation, because I believe it will be prejudicial to our interests to make any change. Very truly yours, W. E. HOLLAND, (S eal) C ashier. THE ANTLERS NATIONAL BANK. A ntlers, Okla., June 17, 1914. (3) T H E FED ER A L RESERVE BOARD. W ashington, D. 0 . G entlem en: T h is b an k desires to express its com plete satisfaction w ith b ein g placed in F ed eral R eserve D istrict N um ber Eleven, to be serv ed from D allas, T exas. In our opinion, Dallas is th e logical p o in t fo r th e S outhern section of Oklahoma, and we should b e so rry , indeed, to b e attac h ed to eith er th e St. Louis o r v>ngftg c ity D is tric t W e a re satisfied th a t w hatever opposition th e r e h a s b een to th e placing of Southern Oklahom a in th e 86 D a lla s D istric t, is d u e to th e a g ita tio n o f p e r s o n s w h o s e p e r s o n a l in te r e s ts w ould b e b e tt e r s e rv e d b y so m e o t h e r a r r a n g e m e n t . R e s p e c tfu lly , A N T L E R S N A T IO N A L B A N K , B y M. D. JO R D A N , C a s h ie r . T H E F IR S T N A T IO N A L B A N K . A y le s w o rth , O k la ., June 4, 1914. (4) T H E FED ERA L R ESE R V E BOARD, W a s h in g to n , D. C. G e n tle m e n : R e a liz in g t h a t t h e r e is a n a t t e m p t b e in g m a d e b y s o m e o f th e b a n k s in O k la h o m a , lo c a te d in D i s t r i c t N o . 11, a n d o t h e r s in th e N o r th e rn p a r t o f t h e S t a te , t o b r i n g p r e s s u r e t o b e a r u p o n you to c h a n g e t h e b o u n d a r y l in e s o f D i s t r i c t N o . 11, s o a s to p la c e th e e n tir e S t a te o f O k la h o m a in D i s t r i c t N o . 10, w e , a s a m e m b e r b a n k o f D i s t r i c t N o . 11, w is h t o s a y t h a t w e h e a r tily e n d o rs e t h e d iv is io n o f O k la h o m a m a d e b y y o u I n o u tlin in g th is D is tric t, a n d w is h t o e n t e r o u r p r o t e s t a g a i n s t a n y c h a n g e w h a ts o e v e r in t h e t e r r i t o r y in c lu d e d t h e r e i n . T h e n a tu r a l tr e n d o f t h e b u s in e s s o f t h e b a n k s o f S o u t h e r n O k la h o m a is n o t to w a r d K a n s a s C ity a n d t h e p l a c i n g o f u s in D is tr ic t No. 10, w o u ld n e c e s s i t a t e o u r f o r m in g n e w r e l a t i o n s a lto g e th e r . T h e S ta te of O k la h o m a sh o u ld b e d iv id e d , f r o m t h e f a c t t h a t t h e s e a s o n s a r e t h e sa m e , a n d t h e c r o p s g r o w n a r e i d e n tic a l w ith th o s e o f th e S t a te o f T e x a s , w h ile t h e N o r t h e r n p o r t io n o f O k la h o m a is t h e s a m e a s t h e S t a t e o f K a n s a s . A t t h e B a n k e r s ’ C o n v e n tio n , h e ld in D a lla s f o r t h e p u r p o s e o f re c o m m e n d in g D ir e c to r s f o r t h e R e g io n a l B a n k , S o u t h e r n O k la h o m a w a s sh o w n d u e c o n s id e r a tio n , b o t h i n g i v in g u s a D ir e c to r, a n d in s e le c tin g B C la s s D ir e c to r s w h o w e r e t h o r o u g h ly id e n tifie d w ith S o u th e r n O k la h o m a i n t e r e s t s . Y o u rs fo r D i s t r i c t N o. 11 to s t a n d , R e s p e c tfu lly , JA S . N. ( S e a l) THE B E N N IN G T O N N A T IO N A L B e n n in g to n , K IN G , C a s h ie r. BANK. O k la ., A u g . 25, 19X4. (S) T H E F E D E R A L R E S E R V E BOARD, W a s h in g t o n , D. C. G e n t le m e n : After studying the situation carefully, 1 am convinced it 87 is to the best Interest of our institution for us to remain in the Eleventh Reserve District. The m atter of having our entire State placed in the District with Kansas City as the center, has been agitated, but owing to the fact that our interests are largely dependent upon the cotton crop, I feel that we «»» be served much better from Dallas than from Kansas City, and therefore write this letter in behalf of our section remaining as it is. Respectfully, L. E. BATCHELOR, President. FIRST NATIONAL BANK OF BENNINGTON. Bennington, Okla., Aug. 25, 1914. (6) THE FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: We desire to express our satisfaction and desire to remain in the Eleventh Reserve District, of which Dallas is the center. We feel that, owing to the fact of our principal re sources being derived from the cotton crop, our conditions and circumstances will be better understood in Dallas than a t Kansas City, and for this reason it is our wish to remain in this District. Respectfully, LEWIS T. MARTIN, Cashier. THE FIRST NATIONAL BANK. Bokchito, Okla., June 4, 1914. (7) HON. FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: W e w ant to protest against any change th a t m ight be m ade in the lines of the Federal Reserve D istrict th a t we are in. The crops grown in Southern Oklahoma are the sam e as th ose grown in Texas and are not the same as those grown in th e Kansas City District. W e think the Committee acted wisely in dividing th e S ta te as they did. Respectfully. TOM KINO, Cashier. 88 T H E F IR S T N A T IO N A L B A N K . B osw ell, O k la., J u n e 15, 1914. (8) T H E F E D E R A L R E S E R V E BOA RD, W ash in g to n , D. C. G entlem en : T h e p u rp o se o f th is l e t t e r is to p r o t e s t a g a i n s t a n y c h a n g e w h a te v e r of th a t p a r t o f O k la h o m a n o w in D i s t r i c t N o . 11, to D istric t No. 10. A t first w e w e re o f th e o p in io n t h a t i t w o u ld h a v e b e e n b e tte r if a ll o f O k lah o m a c o u ld h a v e b e e n in o n e D is tr ic t, e v e n if th e S o u th e rn p a r t w o u ld h a v e b e e n in D i s t r i c t N o . 10; b u t, sin c e stu d y in g th e m a t t e r m o re c lo s e ly , a s t o c lim a te , so il, a n d c ro p s, a n d th e c a ttle a n d s to c k b u s in e s s , w e a r e m o re fu lly c o n v in ced th a t w e c a n b e b e t t e r s e r v e d f r o m t h e D a lla s D istric t, a n d it is o u r h o n e s t o p in io n t h a t t h e s a m e r u l e w ill a p p ly to n e a rly a ll of th e S o u th e rn p a r t o f O k la h o m a . A s s ta te d above, w e a r e a g a in s t a n y c h a n g e w h a t e v e r o f th e N o rth lin e of D is tric t No. 11, in O k la h o m a , a n d o u r a p p e a l to you is, t h a t y o u m a k e n o c h a n g e , a s w e b e lie v e t h a t th e O rg a n iz a tio n C o m m itte e sh o w ed go o d ju d g m e n t i n d iv id in g th e S ta te a s th e y did. Y o u rs v e ry tru ly , W . W . M ORAN, (S e a l) C a s h ie r . THE STA TE N A T IO N A L B A N K . B osw ell, O k la ., J u n e 16, 1914. (9) T H E F E D E R A L R E S E R V E BOA RD, W a s h in g to n , D. C. G e n tle m e n : W e d e s ir e to p r o te s t a g a in s t a n y c h a n g e in t h e F e d e r a l R e s e r v e D is tric ts , so f a r a s th e y r e la te to t h e S o u th e r n p a r t of O k la h o m a . W e b e lie v e t h a t o u r in te r e s ts w ill b e s t b e s e r v e d b y c o n tin u in g in t h e D a lla s D is tric t, b e c a u s e o f th e s i m il a r it y o f t h e c lim a te , soil a n d c ro p s, a n d th e f u r t h e r f a c t t h a t t h e D a lla s B a n k w ill b e m a n a g e d b y a B o a rd o f D ir e c to r s w h o a r e a c q u a in te d w ith th e n e e d s of a b a n k in t h e c o tto n d i s t r ic t . W e b e lie v e t h e O rg a n iz a tio n C o m m itte e sh o w e d go o d ju d g m e n t In d iv id in g t h e S t a te a s th e y d id , a n d w e t r u s t t h a t t h e l in e s a s e s ta b lis h e d w ill re m a in a s th e y a re . Y o u rs v e ry tru ly , W. W. JE T E R , ( S e a l) C a s h ie r. 89 THE CADDO NATIONAL BANK. Caddo, Okla., June 17, 1914. (10) THE FEDERAL RESERVE BOARD, ' Washington, D. C. Gentlemen: There has been considerable discussion lately among the banks of Southern Oklahoma with reference to being placed in District No. 11 with Dallas, and I desire to say that we are entirely satisfied with the condition as it is and certainly hope that no change will be made placing us in some other District. In the first place, I believe that we can get better service from Dallas, because they are nearer to us, and are more familiar with our wants. I believe it would be a mistake to change this part of Oklahoma back to the Kansas City District, as the Organization .Committee would have to give a great deal of time to the consideration of other changes. I respectfully request that no change be made, Yours very truly, <Seal P. P. SEMPLE, PP'MT Cashier. THE FIRST NATIONAL BANK. (11) Colbert, Ind. Ter., June 15, 1914. T H E FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: I understand th at the bankers of Oklahoma City a re m aking an effort to transfer us to Kansas City. I wish to protest ag ain st any change being made, as I feel th a t it is to our in te re st to rem ain as we are. I feel th a t the Dallas D istrict understands our needs and knows our condition b etter th an TTnnaan city , and would be in a better position to assist us. I thfair the Federal Reserve Board acted wisely in placing th is po rtio n of Oklahoma in the Dallas District. Yours very truly, W. H. McCARLEY, (S eal) rre s W e n t 90 T H E H O N O R A B LE F E D E R A L R E S E R V E B O A R D , W ash in g to n , D. C. G en tlem en : T h e officers an d d ire c to rs of th is b a n k a r e t h o r o u g h ly s a t i s fied w ith th e a rra n g e m e n t of th e F e d e ra l R e s e r v e D i s t r i c t s , a n d w e p ro te s t a g a in st th e S o u th e rn p a r t o f O k la h o m a b e in g t r a n s fe rre d to th e K a n sas C ity D is tric t o r a n y o th e r D is tr ic t. W e believe th a t th e O rg an izatio n C o m m itte e u s e d g o o d ju d g m e n t in placing th is p a r t of o u r S ta te in w ith T e x a s , b e c a u s e m a n y of our citizen s a re fro m t h a t S ta te , w e h a v e s im ila r s o il a n d seasons, an d sim ila r crops. W e k n o w th e m a n d t h e y k n o w u s . W e believe th a t a la rg e p a r t o f th e s e n t im e n t m a n i f e s t e d by som e of th e b a n k s in S o u th e rn O k la h o m a i n d e s i r in g t o be tra n s fe rre d to th e K a n sa s C ity D is tr ic t is d u e i n a g r e a t m easu re to th e a g ita tio n b ro u g h t o n b y O k la h o m a C ity . T h e y are in th e K a n sa s City D is tric t th e m se lv e s a n d b e lie v in g t h a t benefit would accrue to th e ir ow n c ity b y h a v in g S o u t h e r n O klahom a tra n s fe rre d to K a n sa s C ity h a v e c o n d u c te d a v ig o ro u s cam paign to b rin g a b o u t t h a t re s u lt. T h e y lin e d u p a g r e a t m any b a n k s in th is p a rt of th e S ta te b e fo re th o s e h a n k s h a d stopped to consider w h a t w a s fo r th e ir b e s t i n te r e s t . W e t h i n k th e e n te rp ris e th ey h a v e show n is w o rth y o f c o m m e n d a tio n , b u t th e n we feel th e B oard should a lso k n o w to w h a t e x t e n t th e y h a v e been activ e in th e effo rt to g e t S o u th e rn O k la h o m a tra n s fe rre d to th e T e n th D istrict. W e believe t h a t a b a n k m anaged by a B o a rd o f D ir e c to r s com ing fro m C olorado, W yom ing, N e b ra s k a a n d t h e o t h e r S ta te s of th e T e n th D istric t, w ould n o t k n o w a n d c a r e f o r o u r n e ed s lik e th e T ex a s b a n k w ould. Y ours v e ry tru ly , (S e a l) JA S. R. M cK IN N E Y , JRM -M ES V ic e -P re s id e n t.. T H E S T A T E NA TIO NAL BANK. D u ra n t, O kla., J u n e 13, 1914. (13) H O N O R A B LE F E D E R A L R E 8 ER V E BOARD, W ash in g to n , D. C. G e n tle m e n : T h is bank d e sire s to e x p ress its sa tisfa c tio n with the F e d e ra l R e se rv e D istric ts a s e stab lish e d by th e O rg a n iz a tio n C o m m ittee. W e believe that o ur in te re s ts w ill b e s t b e se rv e d n by connection with the Dallas Reserve Bank, rather than any other District to which we might be transferred. We think that the Committee showed a thorough consideration of our needs when they separated the cotton growing region of Oklahoma from the other section of the State and placed it along with Texas and the other States which have cotton as their chief product. We respectfully protest against any change being made in our Reserve Bank connections. Respectfully yours, GREEN THOMPSON, GT-MES Vice-President. THE FIRST NATIONAL BANK. Port Towson, Okla., €-23-14. a«> FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: Some time ago we made a protest against having been placed in the Dallas (No. 11) District, but we now want to withdraw our objection, and state that we are perfectly satis fied with said District, as we feel that our interests are more closely allied with the other banks in this District than they would be with those of any other to which we could be at tached. Yours truly, C H A R L IE S W IT Z E R . C a s h ie r. T H E F IR S T N A T IO N A L BA N K O F H A W O R T H . H a w o rth , O k la., A ug. 14, 1914. (15) M R . B. A. M cK IN N E Y , F e d e ra l R e s e rv e B a n k D ire c to r, D is tr ic t N o. E le v en , D u ra n t, O klahom a. D e a r S ir: H a v in g o u r a tte n tio n c a lle d to th e ta c t, b y o u r m u tu a l frie n d , M r. R. D. W ilb o r, o f H ugo, O klohom a, th a t w e h ad failed to file o u r p r o te s t w ith you, p ro te s tin g a g a in s t b e in g a tta c h e d to t h e K a n s a s C ity F e d e ra l R e se rv e D istric t, a s sug* g e sted b y th e K a n sa s C ity a n d O k la h o m a C ity b a n k e r s : In th is c o n n e c tio n b eg to s t a te t h a t w e a r e u n c o n d itio n a lly opposed to b e in g a tta c h e d to th e K a n sa s C ity F e d e ra l R e se rv e 92 District. Kansas City is foreign to us in a financial way, and they are not acquainted with the local conditions of South* east Oklahoma. And we further believe that the Federal Reserve Board acted fairly and impartially in making the division of Okla homa as they did and putting Southeast Oklahoma in the Dallas District, thereby making it possible for the Directors of the Federal Reserve Bank to know the conditions of each locality in their district. You can use the above letter for your authority to file our protest against any change in the Federal Reserve Dis trict No. 11, and if we can serve you further, command us. Yours very respectfully, A. M. HOFFMAN, (Seal) Cashier. THE FIRST NATIONAL BANK. Hugo, Okla., June 16, 1914. (16) FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: We would like to express ourselves as being satisfied in District No. 11. We believe that the lines as they are now drawn, in reference to that part of Oklahoma being In District No. 11, were well defined by the Organization Committeeu This from the fact that the greater part of this section mentioned is a cotton growing country, and naturally should be served by a bank which will be supported largely by this factor. We oppose being annexed to the Kansas City District, and are entirely satisfied in District No. 11. Yours very truly, R. D. WILBOR, (Seal; President. FIRST NATIONAL BANK. Idabel, Okla., June 17, 1914. (17) HON. ORGANIZATION COMMITTEE, Federal Reserve Board, Washington, D. C. Gentlemen: It appears that considerable effort is being put forth by bankers of Ibis State In the 10th District to bring about a change whereby all of Oklahoma would be in the 10th District. 93 At the beginning, we were disappointed, looking at it from patriotic view, in having our State divided in two Districts, but further consideration makes it plain that our interest and that of Texas are very much, the same in industry, and we feel that our interest will be best served in the 11th District. Respectfully, H. C. MORRIS, Cashier. a THE FIRST NATIONAL BANK. Kenefick, Okla., June 6, 1914. ( 18) FEDERAL. RESERVE BOARD, Washington, D. C. Gentlemen: We desire to state that we think the Organization Com mittee used good judgment in placing Southern Oklahoma in the Eleventh Federal Reserve Bank District, as that part of Oklahoma placed in the Dallas District is essentially a cotton producing region. We feel that our interests will be served better by a Board of Directors coming from Texas, Western Louisiana, Southern New Mexico, than one coming from Nebraska, Kansas, Colorado, Wyoming, or any other State that knows nothing of the great problems involved in financing the cot ton crop. Respectfully, BRUCE MAY, (Seal) Vice-President. THE FIRST NATIONAL BANK. Kingston, Okla., June 6, 1914. (19) FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: We wish to commend the action of your Board tn cutting off that part of the State of Oklahoma which is a cotton growing section and attaching it to the Eleventh District. We feel that our interests would be better served by a Board of Directors coming from Texas, the Western part of Louisiana, and the Southern part of New Mexico, than one coming from Colorado, Wyoming, Nebraska, and those other States that know nothing about the problems of a bank 94 c h a rg e d w ith th e d u ty o f fin a n c in g a c o tto n c ro p , a n d w e sin c e re ly ho p e t h a t no c h a n g e w ill b e m a d e in t h i s D is tr ic t. Y o u rs v e ry r e s p e c tf u lly , JN O . L A N D R A M , (S e a l) C a s h ie r , T H E F IR S T N A T IO N A L B A N K . M a d ill, O k la., J u n e 6, 1914. ( 20) ( 21) ( 22) R E S E R V E B A N K O R G A N IZ A T IO N C O M M IT T E E , W a sh in g to n , D. C. G e n tle m en : W e, th e u n d e rs ig n e d N a tio n a l B a n k s o f M a d ill, O k la h o m a , b e lie v e t h a t y o u r C o m m itte e e x e rc is e d a w is e j u d g m e n t in lo c a tin g S o u th e rn O k la h o m a in t h e D a lla s D is tr ic t. G e o g ra p h ic a lly , D a lla s i s c o n v e n ie n t a n d e a s ily a c c e s s ib le to o u r se c tio n ; a la r g e p e r c e n ta g e o f t h e p o p u la tio n o f S o u th e rn O k la h o m a is c o m p o sed o f T e x a n s , w h ic h t e n d s t o a c lo s e r a c q u a in ta n c e of th e tw o p e o p le s, a n d th u s o b v ia te s w h a t m ig h t b e a se rio u s p ro b lem in th e s e le c tio n o f s u ita b le m e n to d ir e c t th e a ffa irs of th e D is tr ic t R e s e rv e B a n k . T h e a g ric u ltu ra l c o n d itio n s a n d p ro d u c ts o f S o u th e r n O k la h o m a a n d T e x a s a re a lm o s t id e n tic a l, a n d t h e b u s in e s s r e l a tio n s b e tw e e n th e tw o s e c tio n s a r e c lo se a n d o f lo n g s ta n d in g . W e u n d e rs ta n d th e r e is a m o v e m e n t to w a r d s lo c a tin g o u r s e c tio n in a n o th e r D is tric t. In v ie w o f th e c o n d itio n s s ta te d a b o v e , w e t h i n k t h e c h a n g e w o u ld b e v e ry u n w ise , a n d w e w ish to e n t e r o u r u n q u a lifie d p r o te s t a g a in s t a n y c h a n g e w h a te v e r. R e sp e ctfu lly , M A D IL L N A T IO N A L BA N K , By J . W . D E R R IC K , C a sh ie r. C IT Y N A T IO N A L B A N K , By W . H . L A W R E N C E , P r e s i d e n t F IR S T N A T IO N A L BAN K, B y P. B. H E R R O N , C a sh ier. T H E F IR S T N A TIO N A L B A N K . S oper, O k lah o m a, 6*17-14. (23) F E D E R A L R E S E R V E BOARD, W a s h in g to n . D. C. G e n tle m e n : T h e R e s e r v e B a n k O rg a n iz a tio n C om m ittee, in e s ta b lis h in g t h e R e s e r v e D is tr ic ts , sa w fit to p lac e S o u th e rn O k la h o m a , in which we are fortunate enough to be located, in District No. In view of the com plaint which has been made in regard to the action of the Board, in dividing the State of Oklahoma between Districts Nos. 10 and 11* the officers Mid directors of The F irst National ytflpir of Soper desire to go on record as being of the opinion th at the interest of Southern Oklahoma and the interest of bank can be better served from Dallas than it can be from City, and to further express themselves as being per fectly satisfied with the action of the Committee of the forma tion of the Bank Reserve District of the Southwest. Yours very truly, A. J. STEEN. (Seal) Cashier. 11, with headquarters in Dallas, Texas. THE FIRST NATIONAL BANK OF STERRETT. Calera, Okla., Aug. 22, 1914. (24) HONORABLE FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: T he officers of th is bank a re satisfied w ith th e action of th e Organization Com m ittee in placing th is p a rt of O klahom a in th e Dallas R eserve D istrict, and p ro test ag a in st an y change in th e lines th a t would tra n sfe r us to an o th er D istrict. As we are in w hat is essentially a cotton-grow ing region, we think we are fortunate in being included in a D istrict whose D irectors so thoroughly u n derstand th e cotton b u sin ess; and especially is th is tru e in view of th e difficulty th a t w ill confront us th is fall in handling th e cotton b u sin ess on account of th e E uropean w ar. R espectfully, J. C. KENTON. C ashier. THE FIRST NATIONAL BANK OP VALLIANT, OKLAHOMA. A ugust 21, 1914. (25) FEDERAL RESERVE BOARD, Washington, D. C. Gentlemen: Relative to the opposition ot the State being divided as to the Reserve Districts, beg to request that any and all oppo sition voiced by this bank, be ignored. 96 W e h a v e gone in to th e p ro p o sitio n a n d fe e l t h a t p la c in g th e S o u th e rn p a r t of th is S ta te in w ith T e x a s , w a s a n a c t of w isdom , ow ing to th e c o m m u n ity o f i n t e r e s t b e tw e e n t h i s se c tio n of th e S ta te a n d T e x a s. T h a n k in g you to a c t in a c c o rd a n c e w ith t h e a b o v e c o v e r in g o u r w ish es, w e a re , Y o u rs tr u ly , T H E F IR S T N A T IO N A L B A N K , V A LLLA N T, O K L A H O M A , (S e a l) B y JA S . M. C E C IL , A tte s t: P r e s i d e n t. W . E . W A T K IN S , C a sh ier. W EW -LCS T H E F IR S T N A T IO N A L B A N K . W o o d v ille, O k la ., J u n e 10, 1914. (26) F E D E R A L R E S E R V E B O A RD , Washington, D. C. G e n tle m en : In th e m a tte r of th e p r o te s t w h ic h is b e in g m a d e o n b e h a lf of th e S ta te o f O k la h o m a b y c e r ta in of t h e b a n k s lo c a te d th e re in a g a in s t th e a c tio n o f t h e F e d e r a l R e s e r v e B a n k O r g a n i z a tio n C o m m itte e , I b e g to a d v is e y o u t h a t i t i s t h e d e s ir e of th is b a n k t h a t th e D is tr ic t r e m a in a s la id o u t a n d d e s ig n a te d a n d , in s u p p o rt of m y p r o te s t a g a in s t a n y c h a n g e , b e g to s u b m it th a t, in m y op in io n , th e in te r e s t s o f t h e b a n k s lo c a te d S o u th of th e C a n ad ian R iv e r in O k la h o m a w ill b e b e s t s e r v e d b y re m a in in g in D is tric t N o. 11, D a lla s, r a t h e r t h a n b y b e in g a tta c h e d to th e 10th R e s e rv e D is tric t, K a n s a s C ity . T h e p rin c ip a l c ro p o f t h is s e c tio n o f th e c o u n tr y i s c o t to n , a n d a ll t h e e x c h a n g e fo r t h a t c o m m o d ity g o e s s o u th e i t h e r t o D a lla s, H o u s to n , G a lv e sto n o r N ew O rle a n s, a n d c a t t l e a n d h o g s a re sh ip p e d m a in ly to F o r t W o rth , T e x a s , w h ile o u r c o rn a n d sm a ll g ra in p ro d u c ts find a m a r k e t e it h e r a t h o m e , o r a r e d is tr ib u te d th ro u g h th e s e s e c tio n s o f T e x a s w h ic h r a is e l it t le feed stu ffa. T h e c h a r a c te r o f t h e soil is p ra c tic a lly t h e s a m e a s t h a t o f T e x a s : th e m a jo rity o f o u r people a r e T e x a s b o rn o r d e s c e n d a n ts fro m T e x a s p e o p le , a n d I c a n n o t se e a n y a d v a n ta g e t h a t c a n r e s u l t fro m a n y c h a n g e in th e d e cisio n o f t h e O rg a n i z a tio n C o m m itte e , w h ile th e r e a r e m an y a d v a n ta g e s t h a t w ill a c c ru e to u s by b e in g so c lo sely in to u ch w ith th e F e d e r a l R e s e rv e B a n k lo c a te d a t D a lla s, a n d I s in c e re ly t r u s t t h a t t h e 07 lin e s , a s o r ig i n a ll y fixed* a t t a c h i n g S o u t h e r n O k l a h o m a t o t h e D a lla s I H s t r i c t N o . 11, w ill b e s u s t a i n e d . V ery tru ly y o u rs, M. U. A Y RES, ( S e a l) C a s h ie r. EXHIBI T O. IN E L E V E N T H D IS T R IC T X ow n C ou n ty B ank * B ry a n • F a r m e r s & M e r c h a n ts N a t ’l. H a n k . A e h l ll e A c h i ll e * B ry a n • F i r s t N a tio n a l B a n k F i r s t N a tio n a l B a n k A da P o n to to c M e rc h a n ts & P l a n t e r s N a t ’l. B a n k A d a P o n to to c F i r s t N a tio n a l B a n k A d d in g to n Je ffe rso n F i r s t N a tio n a l B a n k A le x G ra d y F i r s t N a tio n a l B a n k A lle n P o n to to c C ity N a tio n a l B a n k A ltu s Jackson F i r s t N a tio n a l B a n k A ltu s Jackson F i r s t N a tio n a l B a n k A n a d a rk o C addo N a tio n a l B a n k o f A n a d a r k o A n a d a rk o C addo • A n tle r s N a tio n a l B a n k A n tle rs ♦ P u s h m a ta h a •C itiz e n s N a tio n a l B a n k A n tle rs ♦ P u s h m a ta h a F i r s t N a tio n a l B a n k A pache C addo F i r s t N a tio n a l B a n k A ra p a h o C u s te r A rd m o re N a tio n a l B a n k A rd m o re C a rte r F i r s t N a tio n a l B a n k A rd m o re C a rte r S t a te N a tio n a l B a n k A rd m o re C a rte r A m e ric a n N a tio n a l B a n k A to k a A to k a ♦ F ir s t N a tio n a l B a n k A y le s w o r th ♦ M a r s h a ll B e n n i n g to n • B e n n in g to n N a tio n a l B a n k ♦ B ry a n ♦ F i r s t N a tio n a l B a n k B e n n in g to n ♦ B ry a n B e rw y n F i r s t N a tio n a l B a n k C a rte r B la ir F i r s t N a tio n a l B a n k Jackson B la n c h a r d M c C la in F i r s t N a tio n a l B a n k B o k c h ito ♦ B ry an ♦ F i r s t N a tio n a l B a n k B o s w e ll ♦ C h o c ta w ♦ F i r s t N a tio n a l B a n k B o s w e ll ♦ C h o c ta w ♦ S t a te N a tio n a l B a n k B ro k e n B ow T u ls a F i r s t N a tio n a l B a n k C addo ♦ B ry a n ♦ C a d d o N a tio n a l B a n k C addo ♦ B ry a u ♦ S e c u rity N a tio n a l B a n k C a lv in H ughes C a lv in N a tio n a l B a n k C a lv in H ughes F i r s t N a tio n a l B a n k C h ic k a s h a G ra d y C h ic k a s h a N a tio n a l B a n k C h ic k a s h a G ra d y C itiz e n s N a tio n a l B a n k C h i c k a s h a G rad y F i r s t N a tio n a l B a n k O K L A H O M A N A T IO N A L B A N K S 98 B ank Oklahoma National Bank F irst National Bank Oklahoma State Nat'l. Bank F irst National Bank ♦First National Bank F irst N ational Bank Cordell National Bank F arm ers National Bank State National Bank F irst National Bank Peoples State National Bank F irst National Bank City National Bank Duncan National Bank F irst National Bank *Durant N ational Bank *F irst National Bank ♦State N ational Bank American National Bank F irst N ational Bank F irst National Bank •First National Bank Francis National Bank F irst National Bank National Bank of Commerce First National Bank First National Bank Farmers National Bank First National Bank National Bank of Hastings •First National Bank First National Bank State National Bank City National Bank F. & M. National Bank First National Bank American National Bank Farmers National Bank First National Bank State National Bank City National Bank National Bank of Commerce State National Bank •First National Bank Town County Grady Chickasha Clinton Custer Clinton Custer Coalgate Coal ♦Bryan Colbert Stephens Comanche Washita Cordell Washita Cordell Washita Cordell Custer Custer City Custer Custer City Murray Davis Stephens Duncan Stephens Duncan Stephens Duncan ♦Bryan Durant ♦Bryan Durant ♦Bryan Durant Hughes Dustin Jackson Eldorado Beckham Elk City ♦Choctaw Fort Towson Pontotoc Francis Tillman Frederick Tillman Frederick Kiowa Gotebo Tillman Grandfield Hammon Roger Mills Pittsburg Hartshome Jefferson Hastings •McCurtain Haworth LeFlore Heavener LeFlore Heavener Hobart Kiowa Hobart Kiowa Hobart Kiowa Holdenville Hughes Holdenvilla Hughes Holdenville Hughes Holdenville Hughes Hollis Harmon Hollis Harmon Hollis Harmon Hugo ♦Choctaw 99 Bank ♦Hugo National Bank Fanners National Bank First National Bank •First National Bank ♦First National Bank Keota National Bank •First National Bank First National Bank Peoples National Bank City National Bank First National Bank Lawton National Bank Lehigh National Bank Merchants National Bank First National Bank First National Bank •City National Bank •First National Bank •Madill National Bank First National Bank Mangum National Bank First National Bank Marietta National Bank National Bank of Marlow State National Bank Farmers National Bank First National Bank American National Bank City National Bank First National Bank First National Bank First National Bank First National Bank First National Bank First National Bank First National Bank First National Bank National Bank of Commerce Pauls Valley Nat’l. Bank First National Bank National Bank of Commerce Chickasaw National Bank 'Union National Bank First National Bank Town H u go H ydro H ydro Idabel K eneflck K e ota K in gston K iow a K io w a L aw ton Law ton L aw ton L ehigh Lehigh L ind say L on e W o lf M adill M adill M adill M angum M angum M arietta M arietta M arlow M arlow M aysv ille M aysville M cA lester M cA lester M cA lester Milburn M ill Creek M inco M ountain View N ew W ilso n O lustee P auls V alley P auls V alley P auls V alley Poteau Poteau Purcell Purcell Quinton County •Choctaw Caddo Caddo •McCurtain *Bryan H askell •M arshall P ittsburg P ittsburg Com anche Com anche Com anche Coal Coal Garvin K iow a •M arshall •M arshall •M arshall Greer G reer L ove L ove Stephens Stephens Garvin Garvin Pittsburg P ittsburg P ittsburg Johnston Johnston Grady Kiow a Carter Jackson Garvin Garvin Garvin L e F lore L eF lore M cClain M cClain Pittsburg; 100 First National Bank F. & M. National Bank First National Bank First National Bank First National Bank Beckham County National Bank First National Bank First National Bank First National Bank ♦First National Bank First National Bank *First National Bank American National Bank First National Bank First National Bank First National Bank First National Bank Park National Bank First National Bank Temple National Bank First National Bank Farmers National Bank First National Bank Tishomingo National Bank Farmers National Bank *First National Bank First National Bank National Bank of Verden First National Bank Walter National Bank First National Bank First National Bank First National Bank Waurika National Bank First National Bank German National Bank American National Bank First National Bank Latimer County National Bank •First National Bank First National Bank Southern National Bank Ringling Carter Roff Pontotoc Rolf Pontotoc Rush Springs Grady Ryan Jefferson Sayre Beckham Sayre Beckham Sentinel Washita Snyder Kiowa Soper ♦Choctaw Spiro LeFlore Sterrett ♦Bryan Stigler Haskell Stigler Haskell Stonewall Pontotoc Stratford Garvin Hughes Stuart Sulphur Murray Talihina LeFlore Temple Cotton Custer Thomas Tishomingo Johnston Tishomingo Johnston Johnston Tishomingo Coal Tupelo ♦McCurtain Valliant Grady Verden Grady Verden Walter Cotton Cotton Walter Johnston Wapanucka Washington McClain Jefferson Waurika Jefferson Waurika Custer Weatherford Custer Weatherford Hughes Wetumka Hughes Wetumka Latimer Wilburton ♦Marshall Woodville Garvin Wynnewood Garvin Wynnewood Total number of member banks in the Eleventh D is trict in Soul hern Oklahoma—166. 101 T o ta l n u m b er o f m em b er b a n k s in th e C o u n ties of B r y a n , C h o c ta w , M a rsh a ll, M cC u rta in a n d P u sh m a ta h a , w h ic h a r e e x c lu d e d fro m th e te r r ito r y so u g h t to be tr a n s fe r r e d b y th e C o m m ittee filin g th e p e titio n — 30. T o ta l n u m b e r o f m em b er b a n k s s itu a te d o u tsid e o f th e C o u n tie s o f B r y a n , C h o cta w , M a rsh a ll, M cC u rtain an d P u s h m a ta h a — 136. T o ta l in u m b e r o f m em b er b a n k s r e q u ire d to file p e t i tio n in a c c o r d a n c e w ith th e r e g u la tio n s o f th e F e d e r a l R e se r v e B o a r d — 90.