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http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 115.4 - Section 32, Banking Act of l'an- http://fraser.stlouisfed.org 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-L1.iL"-' 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: http://fraser.stlouisfed.org 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. 72- / v http://fraser.stlouisfed.org 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 1956 I acknowledge receipt of the Board's letter of Aprile+o. 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- http://fraser.stlouisfed.org 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. http://fraser.stlouisfed.org 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 http://fraser.stlouisfed.org 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 http://fraser.stlouisfed.org 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 http://fraser.stlouisfed.org 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 http://fraser.stlouisfed.org 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 http://fraser.stlouisfed.org 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 http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Form F.It. 131 BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM Office Correspondence To _ Files From Lir, Ehae April 3,_1936. Subjecu_ aase Reports by Comptroller of viol tions of Clayton Act and section 32 of the Banking Act of 1933. 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. http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 16-852 http://fraser.stlouisfed.org 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. 0 • ,.:: r .. i RD ' '" '. E.11g.9.1 ) 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 http://fraser.stlouisfed.org 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. http://fraser.stlouisfed.org 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 - 0/36 - 3 ) ' nt2-1 Federal Reserve Bank of St. Louis Respectfully Deputy Comptrol 7R9E(77. OFF1C... ED MAL t;uumal WAR 1936 A:f6....... NUMBEH...ma............. snb &/ft: http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis !,lay 5, 1976. nforcemont ';',ection 72« 'r. Chase, i.ssistal,t http://fraser.stlouisfed.org 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, . oard otatin troller, 4kddressed a memorandum to the 3 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. http://fraser.stlouisfed.org 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, http://fraser.stlouisfed.org 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. http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis FM 140A 7.3f, FEDERAL RESERVE BANK OF NEW YORK Mhrch 18, try Fchuyltr, Ir. Uontgcm, 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 , mnt viol!]tion of the 73ro7 an hpp:, \„ of 19U. 4ccordinay,the 3ohT1 requeOted c.-rnini.i 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 from the atgtutory provisions of the amended act, ,vhich viii be foune on 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- http://fraser.stlouisfed.org 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, refert to organizEtione and Indivic'f.mils "priw,rily ,?,ngliged in thr! IFsue, flotation, und,,Irwriting, 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 , k as not Ingawad to an, eitcnt rhatevr \i\n the typos of business referred 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. . \ Banking Act of 12b5,1 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* http://fraser.stlouisfed.org 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‘ http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis kcjigned) L. P. ENTHCA . http://fraser.stlouisfed.org 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 /711%6 p.1 http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis /3 s-4C, VP ' CZNIz!„:2J, outilleEL MAR c— hUNtith....... 1936 4%?Ci ...... ...... . • tc,c) \,,qw FEDERAL RESERVE BANK 2nERAL RESERVE ilOARD FILE )) \) I by OF NEW YO K 9.133 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 i*ce 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. 1/t. ti e0.16 LA 0 , ALk4, ie4. Ae,.4.1 http://fraser.stlouisfed.org 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. http://fraser.stlouisfed.org 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" http://fraser.stlouisfed.org 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 -,ii,,, ,<(-ce .' . • :::',10 . ,C4',e, OF NEWYORK IO 4 6) 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. http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis n pm r. -- -- 6 .p.0; V •• • FEDERAL RESERVE BANK RECEIVED FEDERAL RESERVE ['MAUD `?-9(1-10-.‘1.0! 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. http://fraser.stlouisfed.org 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, e ,a 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 4/1 44) 4:4„4t,) http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis t 4 51 . 3 I r 1 http://fraser.stlouisfed.org 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. http://fraser.stlouisfed.org 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 .. „Fil: :.,,...././3..,. ,. 1 ,,,,,;(.„ ,,, ,ot,„„ei •1 1 1,,,,,, 1 eri:( Poarcl. 1 ._,.....,...-.......... .....----.1 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, - . John H. Pennsylvania, as of Decem'cer 19, 197.4, states that ? r 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. 41e..f ..4-67)k‘ ei.-41,4a GEC:h1c http://fraser.stlouisfed.org 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. http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Very truly yours, E. H. OUGH, Deputy Comptroller. oPpicz' or 22NERLL cuUNSEL FEB 18 )A14,1-. k ie.•!;,. 4 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 http://fraser.stlouisfed.org 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. .<5. ) ) I/ flhp, Oak*of Often,Oputiiiii 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 http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis .400, OM/ ' 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, 19349 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 R, the applicstion 8-u1,tion 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 http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis RECEIVEP FEDERAL RESERVJ. -,OARD w!,,,-.Likiv Tr; 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 http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis I jfr( Pobr Vowsible 'violation 1:actions 32 by t. •. •'oLo 0 3ireotor, .elrthes, Converoial A*. anima Hr. Chase, -,sststant CoanuO, http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 111. 19isary Se 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. http://fraser.stlouisfed.org 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§ http://fraser.stlouisfed.org 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 —.......... el\ http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • C:.41f11. lik-grO,'.7; 4111 PlIT;' FEDERAL RESERVE BANK OF MINNEAPOLIS' - , 1940 JANI 2 ( 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 giP http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis +.•`" V : 15 Form F. 11. 131 0 irgeiri"45-""*".--114-7 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 http://fraser.stlouisfed.org 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". / http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis FOR FTTY,S 0. W. Bangs http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis rEDERAL RESERVE 3OAHU FILE > ) ) APR 28 1936 Mr. J. d. Thomas, Federal Lieserve Agent, Federal Aeserve bank of Kansas City, Kansas City, .1.ssouri. (-2//St"-/-- Dear Mr. Thomas: r from the board There is inclosed a copy of a lette _ , 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 of l93:7 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. b24444-41#0GHJjrtr1 .d 3ethea, ant 6eore( iI/ f--- azTatt http://fraser.stlouisfed.org 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 http://fraser.stlouisfed.org 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 • (-- LOERAL.RECE14P:'1) FEDERAL RESERVE BANK / ,) 1935 !r) 25 P:1 1 1 27 OF KANSAS CITY OFFICE OF FEDERAL RESERVE AGENT http://fraser.stlouisfed.org 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 of Section 32 of the violation apparent with the E. McGarry's service Mr. W. by of 1933 Act Banking 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 • r 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- /9- http://fraser.stlouisfed.org 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 http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis EL.= LLJ L.1 i. pile .*,-:o. ................. ; ofricj, of C:eneral I Cotinel 1 Fed e t.,1,1 I:::SOITO- 12,w rd,. „....--...„..,..........____....,...................................-.., 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, .41 V GHC:h1c IT.otatcd by. t,pp:oval by. .1;2vi:.,ed by http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis L. P• 3ethea, Assistant Secretary. -it7/v/.3s...... 33.- „Ccf.a.r.fr- e •,,4,,.4.-...,',..0.-.41.. • 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 http://fraser.stlouisfed.org 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 / 5- 6.421:14d http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis http://fraser.stlouisfed.org Federal Reserve Bank of St. Louis