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FRBSF

WEEKLY LETTER

November 9, 1984

The Formative Years
The specific words "independent" and "independence" do not appear in the Federal Reserve Act,
yet they often appear in descriptions of the Federal
Reserve's relationship to popularly elected government. Fromthe provisions of the Federal Reserve Act, and its legislative history, it is abundantly
clear that the Federal Reserve System is intended
to be insu lated as far as possible from the short-term
pressures of partisan politics, but it is just as clear
thatthe Fed is ultimately accountable to Congress.
This Weekly Letterdiscusses the initial concepts of
independence and accountability that found expression in the Federal Reserve Act, and how these
were tested and influenced by a number of events
in the System's1ormative years.
Early concepts
At the start, the Federal Reserve's "independence"
derived to an important extent from its regional
structure and its initially limited menu of responsibilities. To a considerable extent, decisionmaking
was decentralized under the Federal Reserve Act,
which assigned the power and authority of implementi ng the System's goals to the regional Reserve
Banks under the general supervisory authority of
the Federal Reserve Board. The specific goals
included a more "elastic"currency, achieved by
providing a means for banks to borrow currency
and reserves from the Fed, and more effective
bank supervision.
However, early in the System's formative years,
several key events served to redefine the notion of
Fed independence. At the heart of many of these
events was the Secretary of the Treasury, who
served as ex officio member and Chai rman of the
Board of the FederalReserve. Together with his
Treasury colleague and fellow Board member, the
Comptroller, he was in a position to exert considerable influence. And Treasury Secretary (later
Senator) William McAdoo of California was no
shrinking violet. He presided over a number of key
controversies that changed the nature and concept
of Fed independence, and that eventually led to
major changes in the System's structure.
Encounters of the first kind
One controversy involved the efforts, in 1915, of
Board members with strong "centralist" prefer-

ences to eliminate four and potentially six of the
Reserve Banks-Kansas City, Minneapolis, Atlanta, Dallas, Boston and Richmond. These members
included investment banker Paul Warburg, who
had been hosti Ie to some aspects of the Federal
Reserve Act but who nevertheless was appointed
to the Board by President Wi Ison in an effort to
re-establish a spirit of cooperation with the financial community. In making their case, the proponents of reduction cited Warburg's dissatisfaction
with the "petty frame of mind resulting from a
twelve-headed system," but focused primari lyon
the operating losses incurred by the Banks singled
out for elimination in their first year of operation.
Treasury Secretary McAdoo strongly opposed the
move, as did a furious Congressman Glass, author
ofthe Federal Reserve Act. An irate, "decentralist"
President Wilson was prepared to remove the offending Board members "for cause," despite his
prior reluctance to have any contact with Board
members on the grounds that the moment he did
so, "that moment I wou Id be accused of trying to
bring political pressure to bear." The Board backed
off when faced with an opinion from the Attorney
General that only the Congress could reduce the
number of Reserve Banks, notwithstanding the
language the Federal Reserve Act that indicated
there could be fewer than twelve Reserve Banks.
On another occasion, shortly after the System was
operational, Treasury Secretary McAdoo recommended that the Federal Reserve Board be subjected to the congressional appropriations process.
This move was intended to eliminate the Board's
dependence upon the Reserve Banks to finance
its activities, and thereby to remove a potential
source of Reserve Bank influence on the Board.
Board member W. G. Harding subsequently
claimed this was a ploy to make the Board an
ad ju nct of the Treasu ry. On sti II another occas ion,
McAdoo recommended increasing the number of
directors appointed by the Federal Reserve Board
on the boards of each Reserve Bank to a majority
in order to increase the influence of the Federal
Reserve Board over the Reserve Banks.
War finance-calling the shots
The Treasury Secretary's influence on the Board

FRBSF
was most pronounced in matters of "credit policy."
As one raconteur of the Fed's early years noted,
Fed officials at both the Board and the Reserve
Banks had littletimeto "crystallize theirthinking"
on the Fed's role before the U.s. entered the first
World War in the spring of 1917. By thattime, most
countries had abandoned the gold standard because of the dislocations and financing requirements of the war.
One of Treasury Secretary McAdoo's first acts in
this period was to pressure the Reserve Banks into
extend ing to the Treasu ry two tax .Ioans tota II ing
$300 million at interest rates of two and three
percent, respectively. When other Board members
and Reserve Banks balked at offering the Treasury
below-market rates, McAdoo threatened to take
over all the Reserve Banks' funds under the wartime
Overman Act, which authorized the President "to
make such redistribution of functions among executive agencies as he may deem necessary."
McAdoo strongly objected to financing thewar at
market rates. Instead, he urged the Reserve Banks
to set their discount rates, at which they lent to
commercial banks, well below the coupon rates
on current government issues to encourage the
banks to borrow from the Fed and to use the funds
to buy government securities.
The accommodation and faci Iitation of the Treasury's war financing requirements thus became
the primary objective of Fed policy during World
War I. "Everything else," according to the Treasury
Secretary, "was thrown into the background. The
Board necessarily was obliged to follow the policies of the Treasury Department and the Government." From America's entry into WWI through
mid-1919, the federal debt soared from a little over
$1 billion to $25 billion.
Fed officials generally recognized that the rapid
expansion of money and
securities bought
through money creation to support the Treasury's
borrowing requirements were among the causes
of sharply rising prices (consumer prices rose by
over 30 percent during the War), but they differed
as to its importance. Many attributed most of the
increase to shortages of basic materials and com-

u.s.

modities in the face of "swollen" domestic and
foreign demands. The demands, of course, were
themselves swollen by the rapid increase in money
financing, which caused the money supply to rise
by 30 percent.
Accountability
It was clear from the outset that the Congress
intended the Federal Reserve System to remain
accountable to it, notwithstanding the provision
for appointment of the members of the Federal
Reserve Board by the President. (Originally appointed for staggered lO-year terms, Board
members' terms were increased by the Congress
to 12 years in 1933 and then to 14 years in 1935
specifically to provide them with greater insulation
from influence by the Executive Branch. For the
same reason, the Congress in 1935 removed the
Secretary of the Treasury and the Comptroller from
ex officio membership on the Board.)

Early in 1914, the Attorney General ruled thatthe
Federal Reserve Board was an "independent Board
or Government establishment" and not a Bureau
or division of the Treasury (where the Board was
housed), "establishment" being defined by the
U.S. Code as an entity in the Executive branch.
Another expression of Congressional intent as to
whom the Federal Reserve Board was accountable
was the requirementthatthe Board annually make
a fu II written report of its operations to the Speaker
of the House "for the information of the Congress,"
which report would establish a "direct relationship
between the Board and the Congress."
Cornerstone of independence
The Federal Reserve Act and subsequent amendments also gave control over the classification and
compensation of Federal Reserve employees to
the new System (except for the salaries of Board
members, which are set by Congress), and exempted both the Federal Reserve Board and the Reserve
Banks from the congressional appropriations process. At the same time, the Federal Reserve Act
stipulated that all System earnings in excess of
expenses be paid to the Treasury. Over the entire
period from 1914-1983, System payments to the
Treasury have totalled $128 billion, representing

almost 90 percent of the System's gross income
(largely earnings on its investment portfolio). This
aspect of the Fed's finances underscores the public
and governmental, rather than the private, nature
of the Reserve Banks and the System.
Even in the cornerstone of its "independence"-its
financial self-sufficiency, a set of checks and
balances has been built in. The Federal Reserve
System never has been entirely free from audit of
its expenditures. In his 1914 ruling, in which he
determ ined that the Federal Reserve Board was an
"independent government establishment" and
not part of the Treasury, the Attorney General also
concluded that the funds derived by the Board
from its assessments on the Reserve Banks (the
Board's source offunds) were "public monies"
used to pay public officials and therefore were
subject to audit by the Treasury. Following the
establishment of the General Accounting Office
(GAO) in 1921, the Cornptroller cited the Attorney
General's 1914 ruling as a basis for auditing Board

funds, which it did until 1933 when the Congress
amended the Federal Reserve Act explicitly to
preclude audit of the Board (and the Reserve
Banks) by the GAO. However, the Board became
subjectto audit by nationally known, independent
audit firms, while the Reserve Banks were themselves subject to audit by the Board.
More currently, the Federal BankingAgency Audit
Act of 1978 provided for audit by the GAO of each
of the federal banking agencies, including the
Board of Governors, the Reserve Banks and their
branches, but with some carefu Ily defined exemptions. These included the necessarily confidential
and highly sensitive areas of monetary pol icy, open
market operations, and transactions conducted on
behalf of, or with, foreign governments and central
banks. In such ways, Congress continually recognizes and reaffirms the importance of maintaining
the Federal Reserve's independence within
government.
Verle B. Johnston

Opinions expressed in this newsletter do not necessarily reflect the views of the management of the Federal Reserve Bank of San
Francisco, or of the Board of Governors of the Federal Reserve System.
Editorial comments may be addressed to the editor (Gregory Tong) or to the author .... Free copies of Federal Reserve publications
can be obtained from the Public Information Department, Federal Reserve Bank of San Francisco, P.O. Box 7702, San Francisco
94120. Phone (415) 974-2246.

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BANKING DATA-TWELFTH FEDERAL RESERVE DISTRICT
(Dollar amounts in millions)

Selected Assets and Liabilities
large Commercial Banks
Loans, Leases and Investments 1 2
Loans and Leases 1 6
Commercial and Industrial
Real estate
Loans to Individuals
Leases
U.S. Treasury and Agency Securities 2
Other Securities 2
Total Deposits
Demand Deposits
Demand Deposits Adjusted 3
Other Transaction Balances4
Total Non-Transaction Balances 6
Money Mark~t Deposit
Accounts-Total
Time Deposits in Amounts of
$100,000 or more
Other Liabilities for Borrowed MoneyS

Weekly Averages
of Daily Figures

Change from 12/28/83
Percent
Dollar
Annualized

Amount
Outstanding
10/24/84

Change
from
10/17/84

183,961
165,296
49,894
61,119
30,407
5,051
11,548
7,117
189,466
43,339
29,281
12,037
134,091

321
346
263
33
92
2
66
41
774
-1,055
- 408
- 275
557

38,486

452

-

1,111

-

3.3

41,434
20,235

174
1,448

-

3,269
2,772

-

10.3
14.5

Penod ended
10/22/84

-

-

-

7,936
9,941
3,931
2,220
3,756
12
959
1,046
1,531
5,898
2,050
738
5,106

Penod ended
10/8/84

Reserve Position, All Reporting Banks
Excess Reserves (+ J/Deficiency (-)
Borrowings
Net free reserves (+ )/Net borrowedt- J
1

13
102
89

102
67
35

Includes loss reserves, unearned income, excludes interbank loans

2 Excludes trading account securities
3 Excludes U.S. government and depository institution deposits and cash items
4 ATS, NOW, Super NOW and savings accounts with telephone transfers

s Includes borrowing via FRB, TT&L notes, Fed Funds, RPs and other sources
6 Includes items not shown separately

-

-

-

5.4
7.7
10.3
4.5
17.0
0.2
9.2
15.4
0.9
14.4
7.9
6.9
4.7