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F

ed eral

r e se r v e

Ba

n k

O F DALLAS

Dallas, Texas, July 24, 1951

To the Financing Institution Addressed:

The texts o f Bulletins Nos. 5 and 6 o f the national Voluntary Credit Restraint Com­
mittee, which follow, are being forw arded to you at its request.
Y ours very truly,
R. R. G ILB E R T
President

B U L L E T IN N U M B E R 5 OF TH E N A T IO N A L V O L U N T A R Y
C R E D IT R E S T R A IN T COMMITTEE

IN T E R N A T IO N A L FIN AN CIN G
A s a result o f inquiries from regional com m ittees about the status o f foreign borrow ­
ings in United States markets, the national V oluntary Credit Restraint Committee has
discussed the status o f such borrow ings under the voluntary credit restraint program .
The Com m ittee concluded that all such credit applications on behalf o f foreign bor­
row ers should be screened to the same extent, and with the same purpose tests, as
comparable Am erican credits.
It m ay be difficult in some cases fo r financing institutions or regional com m ittees to
determ ine whether a proposed foreign credit would indirectly contribute to defense or
other objectives o f the U. S. Government. It will be particularly desirable, therefore, when
foreign cases are submitted fo r review, that financing institutions subm it full facts to
enable a judgm ent as to purpose. In exceptional cases when a regional com m ittee finds the
facts available to it are inadequate to judge an application, the national committee, if
requested, will endeavor to obtain supplementary inform ation from governm ent agencies.

(Over)

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B U L L E T IN N U M B E R

6

OF TH E N A T IO N A L V O L U N T A R Y

CRED IT R E S T R A IN T COMMITTEE

LO A N S SECU RED B Y STOCKS A N D BONDS
The original statem ent o f principles o f the program fo r voluntary credit restraint
provided that “ the foreg oin g principles (the anti-speculative provisions) should be applied
in screening as to purpose on all loans on securities whether or not covered by Regulations
U or T .” * The first amendment to the statement o f principles deleted the phrase “ whether
or” from the statement. This provision has been the subject fo r a number o f inquiries. For
example, the question has been raised as to whether a loan on securities not covered by
Regulations U or T m ust be screened as to purpose even though the am ount o f credit
advanced m ight be perm issible under these regulations. Such an interpretation would
appear to treat the loans secured by unlisted stocks more severely than those on listed
(i.e., “ registered” ) securities. In order to cure this am biguity, the follow ing principles are
recom m ended fo r your guidance by the national com m ittee:
(1 ) Loans on securities covered by Regulations U or T are basically fo r the
purpose o f purchasing or carrying listed securities. It is recommended, therefore,
that all loans on securities fo r purchasing or carrying unlisted securities be pre­
sumed to be fo r a proper purpose if the amount o f credit extended is no greater
than that perm itted in the case o f listed securities b y Regulations U or T.
(2) Loans on securities, w hether or not listed, but not fo r the purpose o f
purchasing or carrying securities should be made only fo r purposes consistent
with the principles o f voluntary credit restraint.

*The Statement of Principles also provides that “ loans to securities dealers in the normal con­
duct of their business or to them or others incidental to the flotation and distribution of securities
where the money is being raised for any of the foregoing [proper] purposes” should be classified as
“ proper.”