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Federal Reserve Bank of St. Louis

115.4 - Section 32, Banking Act of l'an-


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Federal Reserve Bank of St. Louis

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM
LEASED WIRE SERVICE

WAS H IN GTO N

Your wire December 17 inquiring whether it is
contemplated that you analyze reports and other available information to ascertain apparent violations of
section 17(o) of Public Utility Act of 1975.

Securi-

ties and ;;:xchange Commission is charged with administration of this section, and statement regarding it in
inserted merely

footnote 1 in "l'oardis Regulation L

WAS

as a helpful reminder to bankers.

Therefore ans-i:er to

your inquiry is in the negati7e.
11, P. Bi4 L .iL"-'
-1

Mr. McKee
Mr. Davis
Mr, Flamm
Mr. Clayton
If you appnve, o;eir
and return tn
".";

For ready reference, the statement in footnote 1
of Regulation L referred to in the attached telegram is as
follows:


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Federal Reserve Bank of St. Louis

"Section 17 (c) of the Public Utility Act of 1975
is applicable in certain circumstances to interlocking
relationships between banks and public utility companies and public utility holding companies. Inquiries
regarding this section should be addressed to the Securities and 1!;xchange Commission and not to the Board of
Goirernors of the Federal Reserve System."

FORM

GRAM
• TELE

F.R.246

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM
LEASED WIRE SERVICE

WAS
RECEIVED AT WASHINGTON. D. C.

,greine

43dea
Cleveland dec 17

1120a

e,
‘`

Board
Washn
1936
Is it contemplated by Board's letter of April 18,

(X-9554),,

e information to ascertain
that we analyze reports and other availabl
"Public Utility Act of 1935"
apparent violations of section 17 (C) of
Fletcher
1134a

Lt4.E1L.

LIE

7 36
,c
r.m.

2
7 /

v


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Federal Reserve Bank of St. Louis

f/3 6

NUWAIR_

FEDERAL RESERVE

FEDERAL RESERVE BANK

9 01

OF NEWYORK

April 22, 1956.

,4 -

Subject: Reports by Comptroller of the
Currency of Violations of Clayton
Act and Section 32 of the Banking
Act of 1933

Sirs:
lgml
I acknowledge receipt of the Board's letter of Aprile+o. 1956
w
(X-955)„,in which the Board states that instructions have been issued in the
office of the Comptroller of the Currency that it is no longer necessary to
report to the Board apparent violations of Section 8 of the Clayton Act, as
amended, which may be noted in reports of examination of national banks,
apparently because the provisions of Section 4 of Regulation L, as revised,
provide, in part, that each Federal reserve agent shall cause the information
contained in such reports to be analyzed with a view to discovering apparent
violations of the Act.
The Board further states that it is understood that the same procedure will be followed in the office of the Comptroller with respect to
apparent violations of the provisions of Section 32 of the Banking Act of
19332 as amended, on the assumption that the Federal reserve agents will take
steps, in connection with that section, similar to those prescribed in Regulation L in connection with the Clayton Act.

The Board concludes by stating

that it is assumed that such steps are being taken by this office in connection with Section 52 and, therefore, that it has not suggested_the advisabil-


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Federal Reserve Bank of St. Louis

APP 23 1936
(' _

•

CO

410

FEDERAL RESERVE BANK OF NEW Y

4/22 56.
/

ity of any modifications in the procedure adopted in the office of the
Comptroller with respect to these two statutory provisions.
In view of the fact that the information contained in reports of
examination of member banks continues to be analyzed with a view to discovering apparent violations of both the Clayton Act and Section 52 of the
Banking Act of 1955, I see no reason for any modification in the procedure
adopted in the office of the Comptroller of the Currency with respect to
these two statutory provisions.
Respectfully,

J. H. CASE,
Federal Reserve Age

Board of Governors of the Federal Reserve System,
Washington, D. C.


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Federal Reserve Bank of St. Louis

EDERAL RESERVE BOARD FILE
(.1

/1

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM

X-9554

WAS
ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

April 18, 1936.

SUBJECT:

Reports by Comptroller of Violations
of Clayton Act and Section 32 of the
Banking Act of 1933.

C dad

Dear Sir:
Heretofore it has been the practice of the office of the
Comptroller of the Currency to report to the Board apparent violations of section 8 of the Clayton Act which were noted in reports
of examination of national banks.

Recently, however, instructions

have been issued in his office that it is no longer necessary to
report such apparent violations to the Board.

Apparently these

instructions were issued in view of the provisions of section 4 of
Regulation LI as revised, which provides among other things that
each Federal reserve agent shall cause the information contained in
reports of examination of member banks and other information available to him to be analyzed with a view to discovering apparent violations of that Act.
It is understood that the same procedure will be followed
in the office of the Comptroller with respect to apparent violations
of section 32 of the BanIcing Act of 1933, on the assumption that
the Federal reserve agents will take steps, in connection with that


66p-tc
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Federal Reserve Bank of St. Louis

)
//2,3q

113,002.

-2-

X-9554

section, similar to those proscribed in Regulation L in connection
with the Clayton Act.
It is assumed, of course, that such steps are being taken
by your office in connection with section 521 and therefore the
Board has not suggested the advisability of any modifications in
the procedure adopted in the office of the Comptroller with respect
to these two statutory nrovisions.
Very truly yours,

L. P. Bethea,
Assistant Secretary.

TO ALL FEDERAL RESERVE AGENTS


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Federal Reserve Bank of St. Louis

X-9554
April 18, 136.

SUBJTICT:

Reports by Comptroller of violations of Clayton Act and
section 32 of the Banking Act
of 1933.

Dear Sir:
Heretofore it has boon the practice of the office of the
Comptroller of the Currency to report to the Board apparent violations of section 8 of the Clayton Act which wore noted in reports
of examination of national banks. 'ecently, however, instructions
have been issued in his office that it is no longer necessary to
report such apparent violations to the Board.

iipparently these in-

structions were Issued in view of the provisions of section 4 of
.
Reculation L, as revised, which provides aaon,: other thin„..,s that
each _ederal i:oserve ac,ent shall cause the information contained in
reports of examination of member banks and other information available to him to be analyzed with a view to discoverin_ apparent violations of that Act.
It is understood that the same procedure will be followed
in the of'ice of the Comptroller Jith respect to appnrent -iolations
of section 32 of the Bain

Act of 1&33, on the assumption that

the l'odoral "Aservo a,;ents will take stops, in connection with that


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Federal Reserve Bank of St. Louis

LE'

I ))
E CO

.111

e
r
;
.

me

section, silAilar to those prescribed in ,ez;ulation L in connection
with the Clayton Act.
It is assumed, of course, that such f3tons arc beiv,
taken by your office in connection with section 32, and therefore
the iioard has not sug,,ested the advisability of any i=difications
in the oroced-lro adopted in the office of the Jomptroller with respect to these two statutory provisious.
Very truly yours,
Li PO
. Bethea,
ilssistant 2ecretary.

TO J,1,1, FL,DLakl, RLSERVE AGLNTS

GlIC:h1c
COUNS r
S'OFFICE,
Dictat3d by...

FOR APPPOVAL
F t of Mr.

• ••
.

dr.

Appro./ad by
Mr, !coder
Mr. Szyrnr,
Mr McKee______.

Revisad by

A-Acbtin


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Federal Reserve Bank of St. Louis

Mr. RanRoiti .
Mr Moulson
Mr. Clayton . _

T-2-1

eni

•••

14k

If you approve, pleat*
initia; and return tv
Mrs. Fo.zgerafd

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON
ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

SUBJECT:

Reports by Comptroller of violations of Clayton Act and
section 32 of the Banking Act
of 1933.

Dear Sir:
Heretofore it has been the practice of the office of the
Comptroller of the Currency to report to the Board apparent violations of section 8 of the Clayton Act which were noted in reports
of examination of national banks.

Recently, however, instructions

have been issued in his office that it is no longer necessary to
report such apparent violations to the Board.

Apparently these in-

structions were issued in view of the provisions of section 4 of
Regulation L, as revised, which provides among other things that
each Federal Reserve agent shall cause the information contained in
reports of examination of member banks and other information available to him to be analyzed with a view to discovering apparent violations of that Act.
It is understood that the same procedure will be followed
in the office of the Comptroller with respect to apparent violations
of section 32 of the Banking Act of 1933, on the assumption that
the Federal Reserve agents will take steps, in connection with that


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Federal Reserve Bank of St. Louis

-

- ,

section, similar tb those prescribed in Regulation L in connection
with the Clayton Act.
It is assumed, of course, that such steps are being
taken by your office in connection with section 32, and therefore
the Board has not suggested the advisability of any modifications
in the procedure adopted in the office of the Comptroller with respect to these two statutory provisions.
Very truly yours,
,
t,:lined) L. P. BIL:HE
L. P. Bethea,
Assistant Secretary.

TO ALL FEDERAL RESERVE AGENTS


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Federal Reserve Bank of St. Louis

•

Form F.It. 131

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM

Office Correspondence
To _

Lir,

April 3,_1936.

Subjecu_

Reports by Comptroller of viol
tions of Clayton Act and section 32
of the Banking Act of 1933.

Files

From

Ehae

aase

Assistant Counsel.

G P0

0

dee

Under date of January 28, 1936, Mr. Await issued instructions in the Comptroller's office that apparent violations of the
Clayton Act noted in the reports of examination need not be reported
to the Board, since the Federal Reserve agents received copies of
the reports of examination and were charged with following up apparent violations of the Clayton Act.

Mr. Hodgson, Assistant Chief

National Bank Examiner, read the instructions to me, and also told
me

that he personally had not been reporting such apparent violations

to the Board for several years, since he understood that the Federal
Reserve agents were following them up.
Mr. Yateman, Assistant Chief, Examining Division, advised
me that for similar reasons the Comptroller's office would in the
future not report apparent violations of section 32 of the Banking
Act of 1933 which were noted in reports of examination.

He said that

a memorandum to this effect would probably be issued to the few persons in the Comptroller's office who would be interested.

He did not

feel that there was any hurry about it, however, since there had been
so few of such cases recently (only one since the first of the year).
A letter to the Federal Reserve agents advising them of
this procedure has been prepared.


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Federal Reserve Bank of St. Louis

16-852


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Federal Reserve Bank of St. Louis

R.ETURN TO

GENERAL FILES
•

Y
DO NOT REMOVE AN
PAPERS FROM THIS FILE

4...,.....4.—

.........,,,,..—...—.16irat •......A....i.1.

.....,.....r.......t.,

sf.)nr rill
FEW:. At. !WM/E.

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' '" '. 11g.9.1 i RD
)E.-

FEDERAL RESERVE BANK
OF BOSTON

i936 ,41)1;

April 1, 1936

Board of Governors of the
Federal Reserve System
Washington, D. C.
Gentlemen:
Reference is made to your letter of March 20, 1936 in regard to
the service of Mr. H. J. Sheldon, a director of The First National Bank of
Adams, Adams, Massachusetts, as an employee of Tifft Brothers, Pittsfield,
Massachusetts as being an apparent violation of Section 32 of the Banking
Act of 1933.

We noticed the comment in the report of examination of The First
National Bank of Adams made January 27, 1936.

We wrote to Mr. Sheldon on

March 2, 1936 and he called here to discuss the matter on March 14, 1936.
We have just received a letter dated March 31, 1936 from Mr. Sheldon
advising us that he has tendered his resignation as a director of The First
National Bank of Adams and that the same has been accepted.
Very truly yours,

WEDM:D


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Federal Reserve Bank of St. Louis

Frederic H. Curtiss
Federal Reserve Agent

,

1
se"

Vrederic H. Curtiss,
,
1 oderal Reserve Agent,
1,bderal Resorvo Bank of Boston,
cson,l'assachusetts.
Doar

r. Curtiss:
Thera is inclosod a copy of a memorandum 1.eceived from

the office of the Canotrollor of the Currency calling attention to
the fact that the report of examination of the First National Bank,
Adams, 1Gssachusetts, made January 27, 1936, refers to the service
of T:r. H. J. 3heldon, a director of that bark, as an employee of
fifft irothors, Pittsfield, :'assachusetts, as being an apparent
7iolation of section 32 of the Da.iking Act of 1933.
it will be appreciated if you will investigate the mattcr
and advise the Board of your conclusions.

If you fool that the

question should be considered by the Board, it will be appreciated
if you will furnish the Board with full information and an opinion
of counsel for your bank.
7ory truly yours,
(Signed) I.

p. BE TEMA

L. 7. Bothea,
Assistant ':ecretary.
Inclosure.

GENERAL COUVbleated by
Approved by
Revised b

Ctkp 4"

/
3
Aee •-•vqt.k.
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Federal Reserve Bank of St. Louis

.
1 36
6

•

/
TREASURY DEPARTMENT
COMPTROLLER OF THE CURRENCY
WASH I NGTON

ADDRESS REPLY TO
**COMPTROLLER OF THE CURRENCY"

March 16, 1936.

Memorandum for the Board of Governors of the Federal Reserve System:

For your information and attention you are advised that in
the report of an examination of the First National Bank, Adams, Mass.,
made January 27, 1936, the Examiner states Director H. T. Sheldon
of this bank apparently is serving as an employee of Tifft Brothers
of Pittsfield, Mass., ( Securities Dealers) in violation of
Section 32 of the Banking Act of 1933, as amended, and your Regulation R.


http://fraser.stlouisfed.org - 3 ) /36
-0
'
2
nt -1
Federal Reserve Bank of St. Louis

Respectfully

Deputy Comptrol

7R9E(77.
OFF1C...

ED
MAL t;uumal

WAR
1936
A:f6.......
NUMBEH...ma......
.......

snb

&/ft:


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Federal Reserve Bank of St. Louis

!,lay 5, 1976.
nforcemont

';',ection 72«

'r. Chase, i.ssistal,t


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Federal Reserve Bank of St. Louis

in its Lttor of April 18, 1976 (X•9554), the .;(aard
stated that it und, rstood that the office of the Comptroller
no lual.er Goinff to rort to the ''oard apoirent Tiolations of
:noted in the

sectl r .72 Gf the -.ankinr: Lot of 1!-.177
reports of oAariiinatic_ns of :atior.1 bans.

coputy Comp-

Under date of April 27, 1.76,
.
troller, 4kddressed a memorandum to the 3oard otatin

that the

report of examination of the i.Irst laticta1 iank, Inwood, .iew
York, shoed an apparent violation of section 72 by Director
N. Pearsa11.

I aoeordingly.telephoned 1,7r. Yeatoman, J)zsistant

,xamination Division of the Comptroller's office
Chief of the :
and asked him whether our previous understandin - wax correct.
Po ad7ise6 me thut it was, but that the Lecessary instructions
had not yet boon issued.

he assured me, l:cwever, that they

would be issued promptly.

C. lowland Chase,
Assistant t;ounsel.

7;:rqTRAL .FESERVE 80MiD FILE

TREASURY DEPARTiVIENT
:
-‘)
COMPTROLLER OF THE CURRENCY
WASHINGTON
ADDRESS REPLY TO
**COMPTROLLER OF THE CURRENCY **

April 27, 1936.
C rded

Memorandum for the Board of Governors of the Federal Reserve System:

For your information and such action as you deem advisable, you are advised that the report of an examination of the
First National Bank, Inwood, New York, completed March 28, 1936,
indicates that Director N. Pearsall, who is a partner in the
brokerage firm of W. S. Hernon and Company, has not received
your permission to also act in his present capacity as director
of the subject bank.


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Federal Reserve Bank of St. Louis

4,

Deputy Comptroller.

(
A 1

7.

A.
.C?

NUMBLh-

r'.41.

"

ItEvc1\
FEKRAL RESFPv,
.

FEDERAL RESERVE BANK
OF NEWYORK

1936 t,1,".,n, 19

..1

3 54

March 18, 1936

Subject: Section 52 Status of
Mr. H. R. Johnston

Sirs:
Reference is made to the Board's letter of March 12, 1936,
regarding the applicability of the provisions of Section 32 of the
Banking Act of 1953, as amended, to the service of Mr. H. R. Johnston
as a director of National Bank of Yorkville in New York, New York, New
York, and as president and director of Sterling Securities Corporation,
Jersey City, New Jersey. The Board enclosed a copy of a memorandum received from the office of the Comptroller of the Currency, dated March
4, 1936, quoting a statement from the report of examination of the
national bank as of January 22, 1936, to the effect that the above
described relationship constitutes an apparent violation of Section 32.
In addition, the Board referred to Mr. Dillistin's letter of November
2, 1935, regarding this matter and suggested that if we are still satisfied that Mr. Johnston's relationship does not actually constitute a
violation of the provisions of Section 52, as amended, we inform the
national bank accordingly, in order that it may so advise the examiner
at the time of the next examination.
As suggested by the Board, I have today written to Naticnal
Bank of Yorkville in New York regarding this matter aTi I am enclosing,


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Federal Reserve Bank of St. Louis

•

EDERAL RESERVE BANK OF NEW

.
2

Board of

f the
()
GovernFdal Reservlkstem

3/18/Z6

for the Board's information and records in this connection, a copy of
such letter which I believe is self-explanatory.
Respectfully,

J. H. CASE
Federal Reserve Agent

Board of Governors of the Federal Reserve System,
Washington, D. C.
Enc.


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Federal Reserve Bank of St. Louis

FM

140A

,
7.3f

FEDERAL RESERVE BANK OF NEW YORK

Mhrch 18,
,
Ir. Uontgcm try Fchuyltr,
4
PrerAdent, Nationvi Dank of Yorkville in
York, Nuv York.

11r6

Yrrk,

Dear Ir. Schuyler:
ve
. Eystem has reTho Bobrd of (iovornors of tho Federal !elion
Currency has dra-n it*
(..:ntly advised me tb.,t tha Comptroller of the
attention to th-: fact tht in the report of ex&min6tion of Nations"
Bank of Yorkvillf:! in Ne7 York,
oas w,de to th

WI

of .nuary !;:2, 19Z6, 6 statoment

effoct thht Mr. R.

J8nrtonts service vt the same

tine as a director of the n. on1 b.

president fad director

of Etling Eocurities Coyrcey City, Nor Jersey, constitutes
,
,
an hpp: mnt viol!]tion of the 73ro7

\„
of 19U. 4ccordinay,the 3ohT1 requeOted
i
c.-rnini. this mattel'.

f Section 72 of the

nkin

tct

to communict!te sAth you con-

\,

you probae* kn,/ the provlions of Eection 52 of the Banking Act of 193 er

ended by th,± provivions of section E07 of the Bank-

ing Act of 1955, effective Jnuary 1, 19:. l'or your informfltion in this
.?
connection, there ia enclow?d a copy of th, Board's Legulgtion

at re-

viscid effectivra J:litukry 4, 19n, re17-.tinp; to this subject. You -All note
vhich viii be foune on
from the atgtutory provisions of the amended act, ,
page 3 of the regulstion, thrA no provision is amde for the istutmco of
individual perlits by the Boers and thA 'hereas the stgtute form,,rly
refcrrod to organizwtions "ong,:g,-Id primarily in the busim-ss of pur-


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Federal Reserve Bank of St. Louis

MISC. 140A 9M

Mr. Montgomery Eel/ 14tr,
N/B or Yorkvill-,

7-38

FEDERAL RESERVE BAN0a0
-)QPW 40IIPC

chasing, solline, or negotiuting securities", tht statutqt as alvinded,
?,ngliged in thr! IFsue,
refert to organizEtione and Indivic'f.mils "priw,rily ,
I
flotation, und,, rwriting, public snio, or distribution, at IlloleAe
or rgAsil, or through syndicate particIption, of stocks, encit, or other
similar securities."
The proviout 1--port of FaminPtion of N:tiomR1 B%nk of Yorkville
in Now York contc,inod a statnt regnrding ttir matter similar to the
tIT,t tim. vt-. took np the question ,Ith Nr.

one referred to

,
Johnston. In vitr; of the ftct that his letter to us of Octob-!r n,
contained a AAmt to the effect th'At Ftarling F.:.
'curities Corporation
, not Ingawad to an, eitcnt rhatevr \\ the typos of business referred
k as
in
to in Section 62, as ;nd, c i.

him tYt it app,
:i-ard thbt his

service &f, the same time as c3

ni 31---nk of Yorkville in

Nell York .nd as Tiresident

of ::terlin,, Secnritior Corporation
,
., ,
would not come within therovisionsif Section t2, he zmoned by the
\
-4.
. \
1
Banking Act of 12b5, effeCtis
JunUnr))1, 19Z6. However, if rtrling
EscuritiFs Corpomtiqk ong2gesi,n
referred to In Esction

1 futurc in transactionr 04
'

as amiSndd, to

ny substantiA cYtc.!nt,

7

belifive it would be dasimblo for Ar. Johnston to commnnicate Ath us
re,L3r6114: the matter since ;! furth.,r .luestion might thri be raised as
,,
to th: applicability of the provision:, of th,t section to hie relkAtionship.
I am forvar6ing e copy of this lettr to !
,1r. Johnston for his
informntim and recor6s.
V'ry truly yours,
(Lined)

J. H. Case
J. F. C1S4
Fo=d, ral Reserve Ag,mt
:

Bac*

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Federal Reserve Bank of St. Louis

Jor

MAR 1 2 1936
1,1r. J. H. Case,
Federal Reserve AL;ent,
Federal Reserve Bank of New York,
Lew York, New York.
Dear - r. Case:
in his letar of NoveMber 2, 1935, Hr. Oillistin stated
that, on the basis of the information received by your office, it appeared that section 32 of the Banking Act of 1933 as amended by tho
Banking Act of 1935, effective January 1, 1936, would not be apnlicablo to the service of 'r. H. R. Johnston as a director of !tional
Hank of Yorkville in 'Tew York, New York, Now York, and as president
of Aerlin, ecurities Corporation, Jersey City, Hew Jersey.
There is inclosed a cony of the memorandum received from
the office of tho Comptroller of the Currency, dated T:arch 4, 1936,
quotirk; a statement from the report of examination of the national
bank as of January 22, 1036, to the effect that those relationships
constitute an apparent violation of section 32.

If your office is

still satisfied that the relationshi-)s involved do not actually constitute a violation of section 32, it is ou6gested that you advise the
ban

accordinjy, in order that the bank may so advise the examiner

at the time of the next examination.

Of eourses if there appears to

be doubt as to whether section 32 is applicable, it Is assumed that
you will s91mit tho matter to the Board for its consideration.
GSERALCOUNS 'S OFFICE,

Very truly yours,
11 c.tated
;

by.... . .
.....

t:prond by..
f;v.isod

by

Inolo
/ GHC:h1
3//v/3‘


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Federal Reserve Bank of St. Louis

kcjigned) L. P. ENTHCA
.


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Federal Reserve Bank of St. Louis

TREASURY DEPARTMENT
COMPTROLLER OF THE CURRENCY
WASHINGTON

/

ADDRESS REPLY TO
"COMPTROLLER OF THE CURRENCY"

March 4, 1936.
Memorandum for the Board of Governors of the Federal Reserve System:

For your information and such action as you deem necessary, you are advised that in his report of examination of the
National Bank of Yorkville in New York City made as of January
22, 1936, the National Bank Examiner states:
"Apparent Violation
Apparent violation of Section 32 of the Banking Act of
1933 on the part of Director H. R. IohnEton who is
President of the Sterling Securities Corporation. The
bank does not hold a permit from the Federal Reserve
Board authorizing the continuance of Director Johnston as
a member of the Board of Directors."

Deputy Comptroller.

osi.PJcz

......
Au_

/
1
p.1 /711%6


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Federal Reserve Bank of St. Louis

/3

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VP-4C,
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CZNIz!„:2J, outilleEL

MAR c—

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1936
4%?Ci

......
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.

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FEDERAL RESERVE BANK

2nERAL RESERVE ilOARD FILE
))
\) I

by

3
OF NEW YO K 9.13
November 21 1935.

Subject:

Applicability of the provisions of Section 32 of the Banking Act of 1933 to
the relationships of Mr. H. F. Johnston.

Sirs:
Reference is made to the Board' lett 1935
addressed to Mr. Case, enclosing a copy o a memorandum from the o ice
*
of the Comptroller of the Currency dated September 23, 1935, regarding
an apparent violation of the provisions of Section 32 of the Banking
Act of 1933 by Mr. H. R. Johnston, who is a director of National Bank
of Yorkville in New York, New York, New York and president of Sterling
Securities Corporation, Jersey City, New Jersey. The Board suggested
that we investigate this matter and advise Mr. Johnston with respect
thereto.
We have written to Lir. Johnston regarding the rAtter and,
upon the basis of infornation submitted by him, it appears that his relationships, referred to above, will not come within the provisions of
Section 32, as amended by the Banking Act of 1935, effective January 1,
1936. Accordingly, despite the fact that he has not submitted sufficient information to enable us to determine definitely whether Section
32 in its present form is applicable to his relationships, it does not
appear to us to be desirable, unless otherwise instructed by the Board,
to request Mr. Johnston to submit the further information necessary to
determine the latter question.
Respectfully,

W. H. Dillistin
Assistant Federal Reserve Agent

Board of Governors of the Federal Reserve System,
Washington, D. C.

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Federal Reserve Bank of St. Louis


http://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

DERAL

ri•i:Fr:S;F.P.VE

ODARD FILE

:.Jr. J. H. Caso,
Federal Reserve A,:ont,
Federal Reserve Bank of :law York,
Now York, New York.
Dear Mr. Case:
There is inclosed a copy of a memorandum from the offico
of the 'amptrollor of the Currency dated Septembor 23, 1935, rogarding an apparent violation of section 32 of tho Banking Act of 1933
by :Ir. i. . Johnston, who is a director of The :ational Bank of
Yorkville in New York, :haw York, .;ou York, and president of aorling
reourities Corporation.

It is sug6-osted that you investigate the

applicability of section 32 and adviso Yr. Johnston.

)f course, in

the event that you ar•3 unable, with the assistance of your counsel,
to determine whether or not section 32 is applicable, tho 3oard uill
,
be glad to consider the matter upon receipt of the necessary informs
;ion to;othor with an opinion of your counsel.
Very trul7 yours,

L. 4. Bethea,
Assistant Secretary.
Inclosure.
(31-1C:hlo

1,.
11,,tt.„,4

1

COPY

TREASURY DE?ARTIE NT
COMPTROLLER OF THE CURRENCY
Washington
September 23, 1935.

Eemorandum for the Board of Governors of the
Federal Reserve System:

In the report of a recent examination of The
National Bank of Yorkville In New York, New York City,
The Examiner calls attention to an apparent violation
of Section 32 of "The Banking Act of 1933" on the part
of Director H. R. Johnston, who is President of the
Sterling Securities Corporation. He states the bank
does not hold a permit from the Federal Reserve Board,
authorizing the continuance of Director Johnston as
a member of the Board of Directors.
The foregoing is submitted to you for such
action as you deem necessary.


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Federal Reserve Bank of St. Louis

(signed) E. H. Gough
E. H. Gough,
Deputy Comptroller.

FEDERAL RESERVE BOARD FILE

),
c
TREASURY DEPARTMENT
COMPTROLLER OF THE CURRENCY
WASH I NGTON
ADDRESS REPLY TO
"COMPTROLLER OF THE CURRENCY"


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Federal Reserve Bank of St. Louis

September 23, 1935.

Memorandum for the Board of Governors of the
Federal Reserve System:

In the report of a recent examination of The
National Bank of Yorkville In New York, New York City,
The Examiner calls attention to an apparent violation
of Section 32 of "The Banking Act of 1933" on the part
of Director H. R. Johnston, who is President of the
Sterling Securities Corporation. He states the bank
does not hold a pernit from the Federal Reserve Board,
authorizing the continuance of Director Johnston as
a member of the Board of Directors.
The foregoing is submitted to you for such
action as you deem necessary.

E. H. Gough,
Deputy Comptroller.

RECEIVED
SP 25 1935

urvisiorl OF

EXAMINATIONS

•
FEDERAL RESERVE BANK

-,.' ,<(i,,, ce
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OF NEWYORK

IO

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August 121-435.

Subject:

Possible violation of Section 32
of the Banking Act of 1933.

Sirs:
Reference is made to the Boardes letter to thr. Case of August
2, 1935, concerning the service of Mr. C. E. .t.lheelwright as manager of the
Elizabeth, New Jersey, Office of F. P. Ristine and Company, Philadelphia,
Pennsylvania, and as director of Central Home Trust Company, Elizabeth,
New Jersey. The Board requested us to make such investigation as is necessary to determine whether or not these relationships constitute a violation of Section 32 of the Banking Act of 1933.
Mr. Wheelwright has submitted information regarding the nature
of the business transacted by F. P. Ristine and Company and, upon the basis
of such information, Counsel to this bank is of the opinion that the provisions of Section 32 are not applicable to Mr. 4hee1wright's relationships.
Respectfully,

W. H. Dillistin,
Assistant Federal Reserve Agent.
Federal Reserve Board,

--

‘‘•

-

aashington, D. C.


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Federal Reserve Bank of St. Louis

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FEDERAL RESERVE BANK

RECEIVED
FEDERAL RESERVE ['MAUD

.‘1
`?-9(1-10- .0!

,
f? 1(
) t.

OF NEWYORK

1935 AUG 6 „:1 8

August 5, 1935.

Sirs:
We acknowledge receipt of the Board's letter to Mr. Case
of August 2, 1935, concerning the possible applicability of the
provisions of Section 32 of the Banking Act of 1933 to the service
of Mr. C. E. Wheelwright as director of Central Home Trust Company,
Elizabeth, New Jersey, and as manager of the Elizabeth office of
F. P. Ristine and Company.
We have requested Mr. Wheelwright to furnish us with the
information necessary to determine whether the provisions ofSec—
tion 32 are applicable to his relationships and upon receipt of
his reply we shall advise the Board further with respect to this
matter.
Respectfully,

W. H. Dillistin,
Assistant Federal Reserve Agent.
Federal Reserve Board,
Washington, D. C.


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Federal Reserve Bank of St. Louis

J. 1, Case,
Federal ?esnrve Agent,
Federal reserve Bank of new York,
New York, new York.
Dear !Ir. Case:
The report of examination of Central roma Trust Company,
Elizabeth,

ea
,

orsey, indicates that Llr. C. E. Wheelwright is

s.:
,rving as director of that bank and as manager of the Elizabeth
o'.'ice of 1. P. Ristine and Conpany.
If you have not already done so, it will be appreciated
if you will make such investigation as 1:: necessary to determine
whether or not these relationsh'ps constitute a violation of
section 32 of the Banking Act of 1933, and advise the Board in
the premises.
Very truly yours,

S. R. Carpenter,
Assistant Secretary.
CHC go

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Federal Reserve Bank of St. Louis

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Federal Reserve Bank of St. Louis

•
FEDERAL RESERVE BANK OF PHILADELPHIA
925 CHESTNUT STREET

OFFICE OF THE.
CHAIRMAN OF THE BOARD AND
FEDERAL RESERVE AGENT

RECEIVED
FEDERAL RESERVE E]OARD
W A SI-Ptli7firi'
February 26, 1935.

1935 FEE, 27 Mil 8 !:S
Federal Reserve Board,
Washington, D. C.

Dear Sirs:
Your letter of February 21st, calling our attention to the
fact that the December 19, 1934 examination report of the Wyoming National
Bank of Wilkes-Barre, Pennsylvania, shows that Mr. John H. Brooks, a partner
of the brokerage firm of J. H. Brooks & Company, continues as a director of
the bank in violation of the provisions of Section 32 of the Banking Act of
1933, has been duly received.
We beg to advise you that this matter was taken up with the
bank in March of 1934, at which time we pointed out that the applicant's
relationship was of the type considered by the Board to be prohibited by the
Act and therefore no permit could be obtained.

Mr. Brooks apparently attended

no meetings subsequent to this notification but he did not formally resign as
a director.

We are advised that he was not reelected at the January 1935

stockholders' meetings; thus the relationship referred to is now adjusted.


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Federal Reserve Bank of St. Louis

Very truly y

Chairman of the Board, and
Federal Reserve Agent.
; T j LED
OPPIC'" CT:

FEB 2 1935
NUMBLK

FEB 21 15

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Mr. Richard L. Austin,
Federal Peserve Agent,
rederal Reserve Bank of Philadelphia,
Philadelphia, Pennsylvania.
Dear Mr. Austin:
The office of the Comptroller of the Currency has invited the attention of the Board to the fact that the report of
examination of The Wyoming National Bank of "ilkes-Barre,
Pennsylvania, as of Decem'cer 19, 197.4, states that ? r. John H.
Brooks, who is a director of that bank, is a Partner of J. E.
Brooks & Comnany and has not received a permit from the Federal
Banking
Peserve Board under the provisions of section 32 of the
Act of 1933.
In this connection, reference is made to the Board's
tion, in
letter of March 23, 19A, forwarding to you an apolica
Brooks, induplicate, which had been sent to the Board by Mr.
Regulation R.
stead of to you in accordance with the provisions of
Board as
It will be appreciated if you will advise the
to the status of this matter.
Very truly yourS.
)L. P. BETHT_
L. P. Bethea,
Assistant L7ecretary.

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Federal Reserve Bank of St. Louis

1
(

TREASURY DEPARTMENT
WASHINGTON
COMPTROLLER OF THE CURRENCY

February 16, 195.

ADDRESS REPLY TO
"COMPTROLLER OF THE CURRENCY"

QD
-11

--71

'Li3

Federal Reserve Board,
Washington, D. C.

kr)
RE:

Gentlemen:

THE WYOMING NATIONAL BANK OF NJ
WILKES—BARRE,, PENNSYLVANIA. 1\)

In the report of examination of The Wyoming National
Bank of Wilkes—Barre, Pennsylvania, completed December 19, 1934,
Examiner F. T. Ransom states that Director John H. Brooks is a
partner of J. H. Brooks & Company, investment brokers, and has
not received permission from the Federal Reserve Board to act
as a director of the bank, which is an anparent violation of
Section 52 of the Bank Act of 1933.


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Federal Reserve Bank of St. Louis

Very truly yours,

E. H. OUGH,
Deputy Comptroller.

oPpicz' or
22NERLL
cuUNSEL

FEB 18

)A14,1-.

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.•
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1935
-----.rp

FEDERAL RESERVE BANK OF PH I LADE LPHAkEIVED /// (4,
FEDERAL RESERVE COARD
THIRD DISTRICT
1,711C..!-117,1rTON

RICHARD L.AUSTIN
CHAIRMAN AND FEDERAL RESERVE AGENT
,,

•Nr

ARTHUR E.POST

OFFICE OF THE CHAIRMAN OF THE BOARD
AND FEDERAL RESERVE AGENT

1934 t,,!..A.r? 23 AN1 ,7)

ASSISTANT FEDERAL RESERVE AGENT

ERNEST C. HILL

J

ASSISTANT FEDERAL RESERVE AGENT


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Federal Reserve Bank of St. Louis

March 27, 1934

Federal Reserve Board,
Washington, D. C.
Attention:

Mr. L. P. Bethea,
Assistant Secretary.

Dear Sirs:
In connection with the application of
Mr. John H. Brooks for permission under Section 32 of the
Banking Act of 1933, to serve the Wyoming National Bank
and the J. H. Brooks and Company, we acknowledge the receipt of form 99a, in duplicate, from Mr. Brooks and form
99c, in duplicate from J. H. Brooks & Company, together with
a copy of Mr. Reynold's letter which accompanied the application and a copy of the Board's reply.
Very truly yours,

Arthur E. Post,
Assistant Federal Reserve Agent.

RiCEsvfl

^PUP; nr

1934
P.

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ona timoervt Fk4.
-

MAR 23 1934
Richard L. tustin,
Federal Reserve Lent,
7ederel Reserve Bank of Philedelphia,
Philadelphis, 7ennsylvania.
Dear 'Ir. ,,ustin:
There is inclosed the application, in duplicate,
of "r. John H. Brooks for a permit under Section 32 of
the Banking tot of 1933, together 'with a copy of !Tr.
Eeynolds' letter, whic

accompanied the application.

There

io elso incloscd L copy of the roard's reply.

'Iery truly yours,
' (Si)L.

P.

BETHEA

L. P. Bethea.
hssistent Secretary
Inclosurcs

GHC:hvl

etAt-,41


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Federal Reserve Bank of St. Louis

,
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http://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

1

z

No, _

Dorrance ncynolds, i'resident,
The 74.7aine; National Bunk,
iikes-Barre, ennsylvania.

MAR 23 1984

Dear 3ir:
Receipt is acknowledged of your letter of March 19,
1
9349

inclosing 17,r. John H. Brooks' upplication, in duplicEAs,

for a permit under Section 32 of the Bankint; c -'6 of 1233.
In eccordanco with the repuirements of Section IV(c)
of the Federtll Reserve Board's

8-u1,tion R, the applicstion

should have ben filed with the FodrL1 P.oserve .gent et the
Fedeml Refglerve Bank of your district, in order that he might
ettach his recommendation end forxrd it to the ?ederul Reserve
Board.
;ccordingly,
,
to ttle Federal ::e! erve

r. Brooks' u:plicftion hp° ban runt
gent at the Federal Rcserve P;.nk of

Very truly yourn,
(Signed) L. P. BETHEA
L. P. Bethee,
28sistant Secretary.

GHC:hvl
Copy s(nt to Federal Reserve !gent
at Philadelphia.

FOUNDED 11329

THE WYOMING NATIONAL BANK
THE OLDEST BANK IN NORTH EASTERN PENNSYLVANIA

W1LKES-BARRE.PA.
DORRANCE REYNOLDS
PRESIDENT


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Federal Reserve Bank of St. Louis

RECEIVEP
FEDERAL RESERVJ. w!, ,-.Likiv Tr; ,OARD
,

March 19, 1934.

1934 MAR 21
-1 -"

Federal Reserve Board,
Washington, D. C.
Gentlemen:
I am enclosing in duplicate, application of
Mr. John H. Brooks a director of this bank, for permission
of the Federal Reserve Board to continue to serve as a
director here although a member of a firm dealing in
securities on a commission basis.
There appears to be no way in which Mr. Brook's
membership in his brokerage partnership has, would or
could influence in any way the use of bank credit in this
bank, or have any undesirable effect in any way.
Sincerely,

Dorrance Reynolds.
DR:ALM
Ends.
Application in
duplicate.

CF1VLO
crrTo:
it,!\

1934

A?.,1 3 36


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Federal Reserve Bank of St. Louis

fr
I j(
Pobr

Vowsible 'violation 1:actions 32
by t. •. •'oLo 0 3ireotor,
.elrthes,
Converoial

A*. anima
Hr. Chase, -,sststant CoanuO,


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Federal Reserve Bank of St. Louis

11 19isary Se
1.

I. have your !lenoranllAn of :'obr aftry 11, 193, and tie
.
attaohod lotter late February 7„ 193,3, Prom 'Ir. 71otcer, regarding the sttitus of

!is

unler :,..etion 32

or the 'CAnkini:

Mt or 1933.
!4*. Vlotor statos that 'he has aivised

trat

ho holleves that erottan 32 is roplioable, blt that he hal not yet
been tnformed reg&rdtn

te stes tal:en by 72-4, (1/1Jeo1 to brinr therc

reltalonships Lttto owlformity with the statute.

adls that the

304rd will be f;;Avteed prrtly when such tnformatt,n Is reeeivel.
In the cirollttst)neo, Ihave made a not
matter to vg attewtion in tirty days, unlf1:7
in the nentlo.

Attaohnent

to brIn

the

qdvice is rosivel

Lc
•

11.1.

Mr.
H. Fletcher,
Acting Federal Reserve Agent,
Federal Reserve Rank of Cleveland,
Clevelnnd, Ohio.
Dear Mr. Fletcheri
The reort of examination of the Commercial Bank, Delphos,
Ohio, as of October 19, 1935, refers to the fact that Mr. H. S. McLeod,
a director of the bank, was also a director of Lowry Sweney, Inc.,
Columbus, Ohio, and that he had filcAd an alication under section 32
of the Banking Act of 1933, which

plication was ?ending on the date

of the enactment of the Bunking Act of li135.

Of course, in view of the

fact that the latter Act amended section 32 so as to eliminate the 2rovision regardini); the issuance of individual permits by the Board, nr.
McLeod's applioation is no longer of any effect. However, it will be
appreciated if you will advise the Board whether the relationships involved are still in existence, and, if so, whether in your opinion and
in the opinion of counsel for your bank they are in violation of section
32 and the Board's recently reviscd Regulation R.


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Federal Reserve Bank of St. Louis

Very truly yours,

iC/rwvb

L. P. Dethsa,
Assistant Secretary.


http://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

W. H. Fletcher,
Acting Federal Reserve Agent,
Federal Reserve Bank of Cleveland,
Cleveland, (7-io.
Boar

r. lotchor:
There is inclosed an application in duplicate by '1.„ 7.3.

1:cLeod,undor the provisions of section 32 of the Eanking Act of
1933, for a permit to serve as director of Commeroial Bank, Delpos,
Ohio, and as director of Lowry Sweney„ *Inc., Columbus, Ohio.

The

application was forwarded directly to the Board and is being sent
to you in order that you may attach your reoomnendation pursuant to
soction 1V(o)(iv) of Regulation R.
In view of the prGposed amendments to section 32 now pend..
ing in Congress, you may prefer to defer further action in connection
with this application for a short tine in order to ascertain whether
the section will be amended.
Very truly yours,

Inclosure.
GEC go

S.
Carpenter,
Assistant 3ecretary.

THE CommEncIAL BANK
CAPITAL $ T5,000.00

SURPLUS S 50,000.00

JOSEPH JETTINGHOFF, PRES.
H. M. DAVIES,VicE PRES.

DELPM)SIOIII0

0. G.WEGER,CASHIER

July 251 1935.

ifeLEVIEN

JUL 21, 195;

RECEIVED
FEDERAL RESERVE BOARD

1935 JUL 26

H 43

ammo aff. EDGMA4NM i CO§


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Federal Reserve Bank of St. Louis

Federal Reserve Board,
Washington, D. C.
Gentlemen:
Enclosed herewith please find
the application, in duplicate, of Mr.
H. S. Mc Leod for your permission for
his serving this bank as a director and
at the same time as a director of a
dealer in securities.
Our Board of Directors will
appreciate your favorable action on this
request as it is our earnest desire to
(-have Mr. Me Leod remain with us.
Thanking you for any courtesies
extended, I am,
Yours very truly,
OGA/MH

Cashier.

/

•

t'2,1'17

JUL 26 19 5
isiUMBER

—..........

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Federal Reserve Bank of St. Louis


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Federal Reserve Bank of St. Louis


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Federal Reserve Bank of St. Louis


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Federal Reserve Bank of St. Louis


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Federal Reserve Bank of St. Louis

•

C:.41f11.

lik-grO,'.7;

4111
PlIT;'

FEDERAL RESERVE BANK OF MINNEAPOLIS' -

,
JANI 2 1940

(
IL

NINTH DISTRICT

January 9, 1940

Mr. R. E. Leonard, Assistant Chief,
Division of Examinations,
Board of Governors of the
Federal Reserve System,
Washington, D. C.
Dear Mr. Leonard:
Upon my return to Minneapolis I mentioned to
Mr. Peyton the matter of C. G. Ireys, Director of the
First National Bank and Trust Company of Minneapolis,
also serving as a Director of Wells-Dickey. Mr. Peyton
telephoned to Mr. Wakefield who advised that it was his
understanding that Mr. Ireys had resigned as a Director
of Wells-Dickey.
Mr. Swanson has written to.x22.2,with respect to
the Union Savings Bank, Sioux -Palls, South Dakota, and I
have taken up the matter of definite reference in examination reports to "1 to 10 ratio" with the other examiners
in the department.
I believe this covers all of the matters that
we discussed.
Very truly yours,

H. G. McConnell,
Examiner.

HGM:CJ

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i
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Federal Reserve Bank of St. Louis

+.•`"
V1
:5

Form F. 11. 131

0

irge ri"4 -""*".--114-7
i 5

BOARD OF GOVERNORS
OF THE

8 1940

FEDERAL RESERVE SYSTEM

Office Correspondence
To

Subject: Section 32 - Charles G. Ireys

Mr. Iiesmard.

From

Da

___Einneapolis Minnesota.

Mr. Chase

Your memorandum of Tanuary 30 states that the last
two reports of examination of The First National Bank and Trust
Company, Minneapolis, Minnesota, make no mention of Mr. Ireys'
connection with Wells-Dickey Company but that "Poor's Register
of Directors of the United States and Canada, 198" includes
Mr. Ireys in the list of directors of Wells-Dickey Company,
(although in listing his connections in another section of the
same book, Wells-Dickey Company is not mentioned) and that "Security Dealers of North American describes Wells-Dickey Company
as underwriters, participating distributors and dealers in municipal and other securities.
In the circumstances I think it would be appropriate
(in view of X-9554) to ask the Federal Reserve Bank to ascertain
the facts in order that the applicability of section 32 of the
Bankir

y(A.,--t4-t,t211


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Federal Reserve Bank of St. Louis

Act of 1933 may be determined.

1r‘

41.k

•

FOR FILES
0 W. Bangs
.

Form

•

It. 131

BOARD OF GOVERNORS
THEor

FEDERAL RESERVE SYSTEM

Office Correspondence

Mae January 13, 1939.
Subject:

To

Mr. Leonard

Rona

Glenn M. Goodman_

Charles G. Treys,
Minneapolis, Minnesota.

According to Poorts Register of Directors of the United States and
Canada, 1938, the list of directors of Wells-Dickey Co. includes (page
186) "C. G. Treys, Russell-Miller Milling Co., Minneapolis". The list
of connections of Mr. Treys as shown on page 1859 of the same publication was as follows:
TREYS, CHARLES G. (Born 1884 Boston, Mass.--Univ. of Minnesota
(1900)--V.P., Treas. & Dir., Russell-Miller Millin Co.,
432 Security Bldg., Minneapolis, Minn.
(Residence): 401 Groveland Avenue, Minneapolis, Minn.
First National Bank & Trust Co., Minneapolis, Minn. Dir.
It is noted that the following information regarding Wells-Dickey Company was contained on page 364 of Security Dealers of North America, MidYear 1938 Edition:
\WELLS-DICKEY COMPANY
(i) (MS) (1878) Metropolitan Bank Bldg.
Underwriters, Participating Distributors & Dealers in
Municipal, Foreign, Railroad, Public Utility & Industrial Securities.
Branches--St. Paul, Minn.; Duluth, Minn.
Officers--Stuart W. Wells, Pres.; Joseph L. Seybold,
E. A. Purdy, Robert Y. Stallman, Rollin G. Andrews
& Wadsworth A. Williams (St. Paul), V-Ps.; W. Hubert
Kennedy, V.-P. &Treas.; (MS) Donald H. Brown, Sec.
Mgr. Corporation Dept.--Joseph L. Seybold, V.-P.
Municipal Dept.--Rollin G. Andrews
Mgr. Municipal Trading Dept.--Edward J. Knight
Sales Mgr.--Edward A. Purdy, V.P.
Mgr. Trading Dept.--Theodore W. Felton
Clear Through--Bankers Trust; Continental Illinois Nat.
Bk. & Tr. Co.
Wire Service--Bell System Teletype--MPLS 287
Phone--Atlantic 4201, Private Phone to St. Paul Office
(Cedar 6131) & Postal Phone.
(1)
(MS)

Member Investment Bankers Association of America.
Member Minneapolis-St. Paul Stock Exchange.

Inasmuch as it appears that Wells-Dickey Company is engaged in the general securities business, a question is raised as to whether the services
of Mr. Treys as a director of the securities company and also as a director
of a member bank are in violation of Section 32 of the Banking Ac of 1933.


f_e-,1144/4.,
http://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

FO

FILE

Form F. R. 131
410

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM

Office Correspondence
To

Mr. Chase

From

R. F. Leonard

Subject:

In the last two reports of examination of the\First National Bank
and Trust Company, Minneapolis, Minnesota, as of February 28 and December 27, 1938, no mention was made of Mr. Ireys' connection with WellsDickey. In each report of examination the only connection listed under
the caption "Occupation or principal business affiliation" was as vice
president-treasurer of the Russell Miller Milling Company, Incorporated.
In both reports the definite answer "no" was given in reply to the question (on page 17 of the report) as to whether "any director, officer, or
employee of this bank (a) is a director, officer, or employee of any corporation or unincorporated association primarily engaged in the issue, flotation,
underwriting, public sale, or distribution, at wholesale or retail, or through
syndicate participation, of stocks, bonds, or other similar securities".


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Federal Reserve Bank of St. Louis

FOR FTTY,S
0. W. Bangs


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Federal Reserve Bank of St. Louis


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Federal Reserve Bank of St. Louis

rEDERAL RESERVE 3OAHU FILE
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APR 28 1936
Mr. J. d. Thomas,
Federal Lieserve Agent,
Federal Aeserve bank of Kansas City,
Kansas City, .1.ssouri.

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Dear Mr. Thomas:
board
There is inclosed a copy of a letter from the
_
, Sedan, Kansas,
of directors of The First National Bank of ,'edan
to continue
requesting that :1". Arthur G. Denman be permitted
the Banking Act
as a director of the bank althou h section n of
such director
7
of l93: is apparently applicable to his service as
ny, a bond house in
and as a director of the Rsnson-Davidson Compa
fachita.
such informaIt will be appreciated if you will obtain
regardin
tion as may be necessary and advise the bank

the appli-

ionships.
cability of section 72 to ir. Denman's relat

The lettur

fully understood Footdoes not indicate that the directors have
the Board is no lorv:eir
note 2 in Regulation Rs which explains that
authorized to issue individual permits.
matter should
If upon investication you feel that the
fully as to
be considered by the Board, please advise the Board
counsel for yOUr
the facts in tho case and forward an opinion of
bank with respect thereto.
GEtTE?ALCGU.7:,

Very truly yours,
(Signed) L. P.

kro7ed by
by

L.

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Federal Reserve Bank of St. Louis

•

FERERAL RESERVE BOARD FILE

THE FIRST NATIONAL BANK
OF SEDAN

56

ESTABLISHED 1674

SEDAN, KANSAS
April\:21, 1936
Board of Governors
Federal Reserve System
Washington, D. C.
Gentlemen:
During the examination of the bank by examiner,
R. B. North, in making his comment upon the examination, he states that he believes the relationship
of Arthur G. Denman, who is a director of the Ran-son-Davidson Company, a bond house in Wichita dealing in municipal securitiesi is a viola - ion of regulation "R" of the board of governors of the Federal
Reserve System as of January 4, 1936.
In this connection we would like to state that
Mr. Denman has been a director of the First National
Bank for the past seventeen years. It is the desire
of the entire board of directors and stockholders of
the bank that Mr. Denman be permitted to remain as a
director because of his business experience of banking conditions as they exist in this community and
also his information as to the value of bonds and.:
securities. He is at present chairman of our bond
committee. _We are writing to learn if it is possible
in any way to retain him as a director through permission of the Board of Governors of the Federal
Reserve Sys'cem. As we read regulation "R" in the
appendix we interpret it that this prmission can be
granted by the board. We respectively ask that you
make this exception and allow Mr. Denman to remain.
as a director of this bank.
Yours very truly,

c47
,4w/6w-/
-

Board of iJirectdrs
First Ntional 13, /ak

Sedr/-1(Pnsas


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Federal Reserve Bank of St. Louis

CJi-q

THil: FIRST NATIONAL PANK
OF =AN
SEDAN, KANSAS
April 21, 1976
Board of f.overnors
Federal deserve Eystem
C.
';-Ashinton,
Aintlemen:
Durin the examinatior. of the bank hy examin,
x,
a. J. 1;orth, in making his omment upon tho examination, he states that he believes the relationship
of Arthur i. Denman, who is a director of the Atuson-Davidson Company, a bond lit.use in ,
icl-Ata dealinc. in municipal securities, is a violation of regulation "R" of the board of governors of the i'ederal
iieserve System as of January 4, 1976.
In this connection we would like to state th) t
r. Denman has Leon a director uf the first Natioral
ank for the pt seventeen years. it is the desire
of the entire board of directors and stockholders ci
the bank that r. .,enman co pemittec to remain an a
director because of his business experience of bankconditions as they exist in this comxunity and
also his information as to the value of bonds and
securities. he is at present chairman of our bond
:
e are .:ritinc to learn if it is possinle
committee.
in any way to retain him as a director throu,-h permission of the hoard ,f :;evernors of the iederal
"eserve Eystom. -s we read regulation "3" in the
appendix we interpret it that this permission car be
fronted b. the boar. 43 respectively ask that you
make this exception and allow Mr. Lenman to remain
as a director of this hank.
Yours very truly,
(Sined)

F. Ackerman
Fred Belroyd
H. R. Harshbarger
J. U. Bradley
Lee C. Garrett
Board of Lirectors
First National hank, Sedan, Kansas

•

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RECE14P:'1)
LOERAL.

FEDERAL RESERVE BANK

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1935 !r) 25 P:1 1 1
27

OF

KANSAS CITY
OFFICE OF
FEDERAL RESERVE AGENT


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Federal Reserve Bank of St. Louis

March 22, 1935

Federal Reserve Board,
Washington, D. C.
Attention of Mr. L. P. Bethea,
Assistant Secretary.
Gentlemen:

of_

Reference is made to the Board' letters
March 14, 1935,in connection
XJAnuary31, 1931
apparent violation of Section 32 of the
with the
Banking Act of 1933 by Mr. W. E. McGarry's service
as president and director of the Standard Depositors
Corporation, Denver, Colorado, and as director and
officer of the Union National Bank in Denver, Denver,
Colorado.
We are advised by the president of the Union
National Bank in Denver that at a special meeting
of the board of directors of that bank on March 19,
1935, Yr. McGarry submitted his resignation as
director and officer and that such resignation was
accepted.
Very truly yours,

Assistant Federal Reserve Agent

•

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1..1AP, 2

MAR 14

File No.,./1.a,
40.\ I
Officp of (;(1)era1 Counsel
Ft.-deral Ret,7erve Board.j

,

Mr. A. Y. -cAclams,
Assistant Federal Reserve Agent,
Federal Reserve Bank of Kansas City,
Kansas City, Missouri.
Lear Yr.

Woo.

cAdams:
In its letter of January 31. 1_935, the Board referred to

a statement contained in the report of examination of the Union
Lational Bank in Denver, lenver, Colorado, to which its attention
had been invited by the office of the Comptroller of the Currency.
The statement was to the effect that lirector L. h. ''cGarry of
that bank was president and director of the Standard Depositors
Corporation, Denver, Colorado, that his attention had been directed
to the fact that these relationships apparently were in violation
of section 32 of the Banking Act of 1933, and that he would not be
reelected a director at the annual meeting to be held January 8,
1935.

Accordingly, it GO oared that no further action vas neoes-

sary under section 32.
However, it is understnorl that 'r.
elected a director of the bank.
make such investigation

RS

cGarry has been re-

Accordin„ly, you are reouested to

is necessary to determine whether or not

the provisions of section 32 are apparently being violated and, if
it appears that they are, to advise

r. .oGarry of the steps neces-

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Federal Reserve Bank of St. Louis

J

r. A. E. ;cAdams -- 2

sary to comply with the provisions of that section.

71ease ad-

vise the board of the disposition made of this
matter.
Very truly yours,

L. P. Bethea,
Ls6istart Secretary.

GHC:hlo


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Federal Reserve Bank of St. Louis

EL.=
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JAN si 19.1.5

Mr. A. M. LcAdams,
Assistant Federal Reserve Agent, .
Federal Reserve Dnrilr of Kansas City,
Kansas City, ilissouri.
Dear Ir. cAdams:

The office of the Comptroller of the Currency has called the
attention of the Board to the following statemont contained in the report of examination of the Union National Bank in Denver, Denver,
Colorado, completed on December 24, 1934:
"Director 1. E. -c.';arry is president and director
of the Standard Depositors Corporation, Denver,
Colorado which corporation is engaged primarily in
the business of purchasing, selling and negotiating
securities, and which is in violation of Section (32)
of the Banleing Act of Juno, 1933. :ir..EcGarry as
well as balance of bank's directors have been advised in regard to this violation and Mr. LeGarry's
name will not be submitted to be voted upon as a
director for the ensuing year at the annual stockholders meeting to be held January 0, 1935."
Since it appears that 1:r. :c1:arry is not being reelected a
director of the national bank, it would seem that no further action is
necessary uracr section 32 of the Banking Act of 133, but the above
information is being formardod to you in order to complete your files.
V -ry truly yours,

.4
1

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Federal Reserve Bank of St. Louis

L. P• 3ethea,
Assistant Secretary.

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•
TREASURY DEPARTMENT
WASHINGTON
COMPTROLLER OF THE CURRENCY

January 28, 1935
ADDRESS REPLY TO
"COMPTROLLER OF THE CURRENCY"

IEMORAMUM FOR THE FIDERAL RESERVE BOA...RD:
In re: Union National Bank in
Denver, Colorado.

Ride
In Schedule 17-A of the report of his examination of this
bank completed on December 24, the examiner states as follows:
"Violation of Section (32) of the Banking Act of June


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Federal Reserve Bank of St. Louis

1933.

"Director W. E. McGarry is president and director
of the Standard Depositors Corporation, Denver,
Colorado which corporation is engaged primarily
in the business of purchasing, selling and negotiating securities, and which is in violation of
Section (32) of the Banking Act of June, 1933.
Mr. McGarry as well as balance of bank's directors
have been advised in regard to this violation and
Mr. McGarry's name will not be submitted to be
voted upon as a director for the ensuing year at
the annual stockholders meeting to be held
January 8, 1935."

Li it,L1

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6.421:14d


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Federal Reserve Bank of St. Louis


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Federal Reserve Bank of St. Louis


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Federal Reserve Bank of St. Louis