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Federal Reserve Bank of St. Louis

A CONFERENCE O F GOVERNORS O F THE FEDERAL RESERVE BANKS

Washircten,

D . C.

November 2 , 5 , 1927,

Vester So, -bex,

Washineton,

D y Cys


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Federal Reserve Bank of St. Louis

A CONFERENCE O F GOVERNORS O F THE FEDERAL RESERVE BANKS,

Washington, D . C.,
Wednesday, November 2 , 1927.

The Conference o f Governors o f the Federal Reserve
Banks convened i n the Hearing R o o m o f the Federal R e serve B o a r d , T r e a s u r y Building, W a s h i n g t o n ,

D . C.,

on

Wednesday, November 2 , 1927, a t 1 0 o'clock a.m.
APPEARANCES:

W. P. G. Harding, Governor o f the Federal Reserve B a n k o f Boston;

Benjamin Strong (Chairman), Governor o f the
Federal R e s e r v e B a n k o f 'New York;

Geo. W. Norris, Gevernor o f the Federal R e serve B a n k o f Philadelphia;

E. R. Fancher, Governor o f the Federal Reserve
Bank o f Cleveland;

Geo. J, Seay, Governor o f the Federal Reserve
Bank o f Richmond;
M. B . Wellboarn, Governor o f the Federal Reserve
Bank o f Atlanta;


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Federal Reserve Bank of St. Louis

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James B . McDougal, Geverner o f the Federal
Reserve B a n k o f Chicago;

David C. Biggs, Governor o f the Federal Reserve B a n k o f St.Louis;
. B . Geery, Governor o f the Federal Reserve
Benk o f Minneapolis;
W. d . Bailey, Governor c f the Federal Reserve
Bank o f Kansas C i t y ;

Lynn P. Talley, G o v e r n a

o f the Pederal Re-

serve B a n k o f Dallas:
Wm. A . Day, Senior Deputy Governor o f the
Federal R e s e r v e B a n k o f S a n Francisco;

G. L. Harrison, D e p u t y Governor a f the Federal
Reserve B a n k o f N e w York,

a g d Secretary

t o the Conference

of G o v e r n o r s .
C

The Chairman,
please. I

e

e ee

e

e

T h e meeting will come t o order,

will a s k Mr. Harrison,

a s the first order o f

business, n o t o n the program, t o read a letter which I
have just reeeived f r o m S a n Francisao.

Mrs Harrison, (reading);


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Federal Reserve Bank of St. Louis

"Wy dear Governor Strong:

"I very greatly regret that I am tucapacitated
and shall not b e i n condition t e attend t h e conference, N o v e m b e r e d .
"Te b a n k will,, therefore,

b e represented

by

Mr. Wm. A . Day, Senior Deputy Governor, a n d I trust
thet y o u will treat h i m with a greater degree o f
tenderness t h a n I

c a n e x p e c t f o r myself,

a s well as.

extend t o him a n y usual courtesies c f the conference.

"Please present m y greetings t o all those attending, a n d express m y regret t h a t ¢

shell n o t b e

able t o s e e t h e m o n this occesicn.

"Yours very truly,
"Jno. U. Calkins,

"Governor."
The Chairman yesterday, a f t e r receiving this letter,
dispatched t h e following telegram:

"Many thanks fer your letter just reecived.

W e

promise t o treat D a y tenderly o u t o f consideration
for y o u r t e n d e r f e e t a n d a l l h e a r t i l y j o i n i n r e grets a t y o u r a b s e n c e a n d w i s h e s f o r a

speedy a n d


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Federal Reserve Bank of St. Louis

complete recovery."
The Chairman.

I f there {fs n o objecticn, t h e action

of the Chairmen i s approved.
Governor Bailey. I

so move.

The Chairman. Y o u see what i s ahead o f yeu, Mr.Day.
The Open Market Committee yesterday h a d a meeting
which t o o k the entire d a y and considered certain memoranda
that were submitted a s a preliminary statement u p o n which
the c o m m i t t e e b a s e d a

report a n d r e c o m m e n d a t i o n

as to

policy a n d pregram f o r the next f e w months, a n d I

am

going t o ask the secretary t o distribute t h e memoranda
and urge that t h e members o f the Conference w h e have n o t

had opportunity t o read i t study i t i f it is pessible
just a s secon as possible.

(The Secretary distributed the memoranda referred to.)
The Chairman (continuing). I

weuld also like t o an-

nounce that t h e Federal Reserve Board h a s arranged a meete
ing o f the Open Market Committee i n this r o o m I believe,
at 1 1 o'clock,

a n d that meeting will likely last a n

hour o r a n hour a n d a half, a n d then o u r Conference
can reconvene.

T o p i c s Ne. I

A, B

and C

o n the program,

which a p e t h e u s u a l o n e s t h a t a p p e a r a t t h e t o v o f e a c h

program, a l l more o r less relate t e the discussion that


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Federal Reserve Bank of St. Louis

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will ensue upon t h e report o f the O p e n Harket Committee,
I suggest t h a t w e defer consideration o f these three
topics until after t h e meeting o f the Open Market Com.
mittee w i t h t h e F e d e r a l R e s e r v e Beard.

objection?

T h e r e being n e objection,

I s there a n y

w e will proceed

to Topic I-D:

I. D. Advisability o f requiring member
bank o f f e r i n g f o r r e d i s c o u n t p a p e r o f

Corporations having subsidiaries t o
have i n i t s f i l e s r e c e n t C o p i e s

of

separate financial statements o f the
subsidiary corporations, w h e n there
have been filed with Federal Reserve
Banks copies o f the ecerporation's
consolidated financial statement a n d
the individual financial statements
of all subsidiary corporations.

The Chairman (continuing). This topic was suggested

by the Federal Reserve Board, but I think arose i n cornection w i t h a n inquiry made b y a Federal Reserve Banik.
Will t h e guilty party diselose w h o made that inquiry?
Governar Geery. I

a m guilty.

The Chairman, M r . G e r r y o f Minneapolis. W i l l y o u
state t h e q u e s t i o n t h a t t h e C o n f e r e n c e
Goevefnor,Geery.

i s t o ccnsider?

T h e question c a m e u p originally

on the paper o f the Washburn-Croesby Company o f MinneapoBiss

T h e y furnish a consnlidated statement a n d

have eight subsidiary cerporations, n o n e o f whieh a s k


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any ercdit whatever f r o m the public aside f r o m what
little t h e y m a y n e e d i n t h e w a y o f rental, l e a s e a n d
stationery p u r c h a s e s a n d t h a t s o r t o f thing, a n d t h e y

furnish u s a n d a l l the other Federal Reserve Banks w i t h

individual statements o f all these companies, t h e individual statement o f the Washburn-Crosby Company a n d the
ecnsolidated statement, b u t t h e y cbject t o furnishing a l l
of t h e s e s t a t e m e n t s
may b u y t h e i r paper.
their brokers,

t o e v e r y Tom, D i c k a n d H a r r y t h a t
I n fact, t h e y d i d n e t g i v e i t t o

a n d w e h a v e a l w a y s t a k e n t h e paper,

and

I find that Chicago d i d a n d Cleveland did, under those
circumstances.

T h o s e were t h e only t w o benks I

and the o n l y one that I

asked,

feund c u t that d i d not was N e w

York.
n. T h e n w e are t h e other guilty party.
Our p o s i t i o n i s , briefly, t h i s , t h a t w e b e l i e v e t h a t i f

the regulation a s i t now stands i s enforced, t h a t t h e
¢oncerns w h i c h h a v e s u b s i d i e r i e s

a n d wish t o g e inte t h e

market w i t h their paper, w i l l i n fact furnish t h e statements t o their banks, t h a t is, t o the member banks w i t h
which they keep their accounts, a n d i f they a r e furnished
to these panks a n d those banks furnish t h e m t o us, t h a t
would satisfy .the situation a s t o the paper t h e y sell


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Federal Reserve Bank of St. Louis

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on t h e maricet.

O n t h e o t h e r hard, t h e y a r e unwillizeg

to furnish statements, b u t wish t o make paper, whether
it i s commercial paper that sells i m the o p e n market
or a

paper t h a t g o e s d i r e c t l y t o t h e banks,

w e feel that

we are t o some extent passing o n the credit o f that concerx for t h e benefit o f the member b a n k o r the broker,
or the beste Auge t h e paper f r o m t h e broker, a n d w e are

sharing i n e less degree, but nevertheless that i s the
position w e would b e i n o f passing e n the credit o f a

statement from makers o f paper generally i n order t o make
them eligible, even though their banks d o not receive
that s t a t e m e n t .

W

e have a

case

o f that sort t h a t

has b e e n u p repeatedly i n New York, a n d that i s McFadden
in Philadelphia. I

story very fully.

think G o v e r n o r N o r r i s k n o w s t h a t

T h e y sought t o file a

copy o f their

statement w i t h t h e F e d e r a l R e s e r v e B a n k o f N e w Y o r k i n

order that w e might take their paper, even though that
statement w a s n o t o n file w i t h the member bank.
Governor Norris.

M s y I interrupt y o u there t o s a y

that t h e y d o n o t s e l l o r i n d o r s e a n y c o m m e r c i a l paper.

The Chairman. N o , but I

a m using that a s a n extreme

illustration o f a case where t h e y could s a y t o their b a n k

"To be sure, w e did net furnish a statement o f our affairs,


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but i t i s o n file i n the Federal Reserve Bank, a n d t h e
Federal R e s e r v e Banke w i l l t a k e t h i s p a p e r f r o m
you,"

and then the member bank will say, “Of course, i f the
Federal Reserve B a n k will take 1¢, thet i s all right."
To a less degree that i s true o f such a gase a s t h e
Washburn-Crosby Company;
York.

W

a t ieast,

w e feel s o i n New

e have drawn o f f a list o f the concerns o f
like

character t o the Washburn-Crosby Company which, because
of the regulation, h a v e filed t h e subsidiary statement
with t h e i r b a n k s

o r w i t h t h e vro,ers.

the s t a t e m e n t h a s c o m e t o u s f r o m a
bly h a s t h e a c c o u n t

I n every instance

bank w h i c h presuma-

o f t h e m a k e r o f t h e paper.

it when w e sit tight o n the regulation.

T h e y do

T h e question

1s whether i t i s well t o begin t o make exceptions a n d
whether w e can d o i t and nevertheless m a k e i t effective.
Governor Faneher.

D o I understand, M r , Chairman,

in your preliminary statement that paper o f a eancern

that was sold i n the market, i f this statement was furnished t o the banks w i t h whom they earried their depositary
account, t h a t that might suffiee,

o r d o you g o s o far a s

to make i t a requirement o r think i t should b e a requirement i n the regulation that t h e bank buying t h e note o f

such a concern for $5,000 o r $10,000 should i n turm have


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Federal Reserve Bank of St. Louis

all those ststements?
The Chairman.

I f a n y bank offering paper o f the

Washburn-Crosby Company should come t o u s with a state-

ment i n the form the regulation requires, that would an»swer t h e purpose f o r t h e bank, whether i t came f r o m the

bank i n which they kept their account o r a bank that
bought i t from brokers, a n d all they have t o d o 41s for
the Washburn-Crosby Company t o file a complete statement
in accordance with the regulation.
Governor Fancher. A

complete statement o f the parent

company a n d the subsidiaries?

The Chairman. Yes, a n d that clears them.
Governor Fancher.

from a broker,

S o that e a c h bank buying that note

i t would b e incumbent o n that b a n k t o say

that i t h a d the statements pefere t h e paper w a s accepted,
or 1 t would n o t b e i n a position t o discount t h e paper?
Governor Bailey.

Suppose a

country b a n k sends i n a

$5,000 note o f the Washington-Crosby Company that they
have bought from a broker, t o our bank, a n d w e have the
Washburn-Crosby reports, both the subsidiaries a n d the
original, a n d this 1 s a solvent bank that sends i t t o us,
have t h e y g o t t o send i n this report?
The Chairman.

o u r procedure i n New York would b e


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this, a n d Mr. Harrison will correct m e i f I a m not right,
that t h e Washburn-Crosby Company probably have a n account
in New York?
Governor Geery.
The Chairman.

W i t h t h e Chese National Bank.

I f the regulation w a s complied with

it would b e met b y the Chase o r the N e w York Trust Conpawy filing a statement, a n d when that paper c a m e i n from
would g o before t h e committee a n d they would
We d o n o t r e q u i r e t h e s t a t e m e n t w i t h e v e r y

piece o f paper that comes in.
Governor Bailey. T h a t i s what I mean.
Governor Fancher.

Y o u a s k that t h e paper f r o m t h e

offoring bank i f they have a statement o n file?
The Chairman. YoSGevernor Fancher.

D

e y o u pursue t h a t t o the point

where that i s simply t h e consolidated statement,

o r state-

ments o f all o f the subsidtlarics?
The Chairman.

W e always d o .

Governor Fancher. I n other words, y o u ascertain what
of a statement t h e y have got?
The Chairman.

Yes.

T h e y merely certify--

Governor Fancher (interposing).
statement?

T h a t t h e y have a


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The Chairman. That they have a statement.
Governor Fancher.

D o y o u pursue that t o a point

where t h e y have simply got t h e consolidated statement o r
the consolidated statement a n d t h e statements o f the subsidiaries?
The Chairman.

N o .

T h e n it is a

question c f whether

we have g o t i t from some other bank.

Governor Fancher.

A n d the offering bank certifies

that t h e y h a v e t h e statement,

a n d y o u a c c e p t t h a t “ o n the

assumption that t h e y have g o t t h e statement t h a t y o u have
got?
The Chairman.

W e are n o t passing o n the credit f o r

them.
Governor Bailey.
burn-Crosby s t a t e m e n t

B u t y o u originally have t h e Washi n the N e w York Bank?

The Chairman. Y e s .
comes

T h e r e i s some o f this paper t h a t

i n e v e r y d a y almost.

Governor Bailey. I

am thinking about our situation,

where t h e Washburn-Crosby Company has n o t got a n y account
in Kansas City, a n d a member b a n k buys a

piece o f paper

from a broker a n d sends i t i n for rediscount.

W e think

it i s good, a n d have w e got t e call o n the member bani
that s e n d s

i n t h a t {$5,000 n o t e t o f u r n i s h u s i t s s t a t e m e n t


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Federal Reserve Bank of St. Louis

in every case?
The Chairman. I

do not know h o w itt i s done now, b u t

the w a y w e used t o d o it, t h e Reserve banks exchanged i n formation about paper i n their respective districts, a n d
there 1 s a resolution o n file o f the Governors! Conferencé, w h e r e p a p e r w h i c h o r i g i n a t e s

i n another district,

and i s distinctively paper o f that district a n d i s offered
in o u r district,

w e telegraph t h e other Reserve b a n k a n d

get t h e statement f r o m them. T h a t used t e b e done.
Governor McDougal.

D e e s t h e Washburn-Crosby Company

file their complete statement w i t h their depositary banks?
Governor Geery. T h e y have n o t this year.
Governor McDougal,

T h a t i s the o n l y weakness i n that

case?

Governor Geery.
3°

J u s t look a t this a n d see h o w b i g a

2 0 46.

Governor McDougal. I

know what i t is, a n d i t would

be useless i n the hands o f most banks, anyhow.

Y o u know

that.
Governor Geery. Yes, sir.
Governor iicDougal.
a suggestion,

M r . Chairman, I

i f I may. I

would like t o make

think this whole matter c a n b e


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Federal Reserve Bank of St. Louis

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dealt w i t h s a t i s f a c t o r i l y a l o n g t h e l i n e s y o u h a v e r e c ommended,

a n d here i s a

memorandum t h a t w e prepared r e -

lating t o the subject, t h a t t h e matter c a n b e satisfactorily dealt with through t h e adoption o f the recommendation made b y the Advisory Council i n September, w i t h a

slight modification, t h e Council's recommendation being
that s u c h companies should b e required t a file with their
banks o f deposit a
statement

consolidated statement a n d a detailed

o f a l l subsidtiaries. I

consideration

would s u g g e s t f o r t h e

o f the Conference t h a t w e adopt t h a t a s o u r

procedure with one slight modification, and that is, instead o f saying "banks o f deposit,” s a y "principal banks

ofdeposit," and I think that would take care of brokers!
paper a l o n g t h e l i n e s w h i c h y o u s t a t e d w o u l d b e satisfact-

ory, a n d i t would place i n the hands o f the principal d e positary b a n k s w h a t t h e y d o n o t g e t n o w f r o m s o m e c o r p o r a -

tions.
Governor Fancher.

D o y o u think that would take care

of the broker situation?
Governor MeDougal. I

the broker situation.

think t h a t w o u l d t a k e c a r e o f

I t i s quite i n accord with

Governor S t r o n g ' s n
w
o recommendation.
The Chairman.

M r . Harrison h a s t h e record

o f that

meeting a n d t h e action taken i n the Advisory Council.


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Federal Reserve Bank of St. Louis

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Weuld y o u report that, please, M r . Harrison?
Governor Seay.

T h e danger which y o u have i n mind

is not a n imaginary one.

I

t i s a real one.

T h e

Federal reserve banks should n o t c o n s e n t ‘
t
o be placed
in t h e p o s i t i o n w h e r e t h e y w o u l d b e c o n s t r u e d

b y their

member banks t h a t t h e y passed u p o n t h e credit o f these
people.

The Chairman. T h a t i s the thought.
Mr. Harrison. L a s t September

a t the meeting o f the

Advisory Council, t h e question h a d been raised whether
something ought n o t t o b e done t o alleviate this condition, especially a s the Advisory Council s a i d that this

requirement o f the Board was resulting i n a decreasing
supply o f eligible: c o m m e r c i a l paper.

A f t e r considera-

tion b y the meeting, t h i s action was taken:

"Attention has also been called t o the Federal
Advisory C o u n c i l t h a t t h e v a r i o u s F e d e r a l r e s e r v e
banks h a v e d i f f e r e n t p r a c t i c e s a n d r e q u i r e m e n t s
to t h e f o r m a n d c h a r a c t e r

filed b y the companies.

o f the statement

as

t o be

T h e Federal Advisory Council

believes t h a t t h e r e q u i r e m e n t s

a s t o statements

should b e standardized, a n d that companies having


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Federal Reserve Bank of St. Louis

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one o r m o r e s u b s i d i a r i e s s h o u l d b e r e q u i r e d

to

file with the banks o f deposit a consolidated
statement a n d a detailed statement o f all their

subsidiaries."
That action o f the Federal Advisory Council w a s discussed i n the record over a

period o f some t e n pages, a n d

at the conclusion, while n o definite action was taken b y
the Council, G o v e r n o r S e a y , I

think i t was, s u m m a r i z e d t h e

discussion b y saying:
"The g e n e r a l o p i n i o n i s t h a t t h e r e g u l a t i o n

of the Board should b e complied with."
That was apparently the consensus o f view o f the
Council a t that time. W h e n I reported the discussion t o
the Federal Reserve Board, I

did not indicate t h a t a n y

action h a d been taken, because a s a matter o f fact none
had expressly been taken a n d there was n o vote. E v i d e n t l y ,
in view o f the fact that t h e Conference d i d not formally
vote o n compliance w i t h the Board's regulation, t h e matter
has b e e n referred back t o us; b u t there i s n o doubt,

in

reading these t e n pages o f the stenographic record, t h a t
this case was precisely t h e same a s the o n e n o w under discussion,

a n d s o considered

b y t h e Conference,

a n d the

feeling was that the regulations o f the Board should b e


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complied with a n d that i n all cases-<not j u s t i n New
York, a s has b e e n t h e practice, b u t i n all cases==the
statemesats o f the borrowers a n d i n d i v i d u a l statements
of the subsidiaries should b e o n file with t h e member
bank a n d not merely with t h e Federal Reserve Bank.

Governor McDougal. I f you take that literally, that
g e t

e e t h a t every bank offering a paper purchased

from a broker would have t o have t h e statement.
Mr. Harrison. I

think that i s a perfectly accurate

construction o f the present regulation o f the Board,
The Chairman. I

d o not t h i n k that i s what w e ag, < — f

think w e accept t h a t l e t t e r S

i n the application f o r m a g

indicating that a statement i s o n file with the offering
member bank, w h i c h i s satisfactory t o that bank, a n d then
we turn t o i t i n our credit files t o see whether t h e statement o n file with u s i s satisfactery t o us.
Governor Fancher.

A n d which has come t o y o u from a

member bank?
The Chairman. Yes; b u t I

do not think w e checked that

back.
Mr. Harrison. I

think i t i s perfectly true that w e

do not check back the meaning o r the significance o f the
letter S

i n the application, b u t i n every case where w e


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have specifically asked t h e question, w h e r e w e have a p y
information contrary,

w e expect t h e m t o have a consoli-

dated statement a n d also separate statements o f the subsidiaries,
Governor Bailey. T h a t would revolutionize t h e
buying o f commercial p a p e r b y c o u n t r y banks.
Governor Fancher.

I s i t necessary f o r t h e concern

making t h e paper t o furnish a statement o f the parent
company a n d t h e subsidiaries,

a n d i n addition t o that

furnish i t t o t h e p u r c h a s i n g b a n k i f t h e b a n k e x p e c t s

to rediscount t h a t with t h e Federal Reserve Bank?
The Chairman. T h e actual practice, I

think, i s this,

that when t h e member b a n k sends i n the application f o r m

with the letter S$ on it, i t is assumed that the statement
held b y that member b a n k i s i n conformity w i t h the Board's

regulation, whether i t is o r not, a n d the responsibility
rests u p o n t h e m e m b e r b a n k s t o h a v e t h e s t a t e m e n t

form required b y the regulations.

i n the

W e cannot check u p

every transaction t o see that t h e y have.
Governor Fancher.
The Chairman.

W e d o not attempt to.

Q u r responsibility

i s t o see that a

member bank has given us a statement which complies with
the regulation,


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Federal Reserve Bank of St. Louis

Governor Fancher.
The Chairman.

T h a t i s the point,

B u t w e d o not require statements f r o m

the member bank.
Gavernor Geery.

M y recollection i s that t h e regula-

tion o f the Board requires t h a t bankers! acceptances,

to

be eligible f o r purchase, t h e Federal Reserve B a n k pur-~
chasing most hévthe statement o f the acceptor showing
a s a t i s f a c t o r y condition,

strength o f J. P.Morgan &

a n d y e t w e b u y paper

o n the

Company having furnished y o u

with a statement.
The Chairman.

O f course, t h e y are n o t member banks.

Governor Geery.

N o , b u t i f the First National B a n k

of Minneapolis h a s some J . P. Morgan acceptances w h i c h
they wish t o indorse--

The Chairman (interposing).
history behind that.

W e l l , there i s a long

I n the early days these b i g bank-

ers never made a statement t o anybody i n the world, n o t
even t o their o w n banks.

T h e y never borrowed o n their

paper without collateral, a n d w e had a special rule o f
the Board which permitteg t h e Federal Raeserve B a n k o f
New Y o r k t o p u r c h a s e a c c e p t a n c e s

o f private bankers u p o n

the f a i t h o f a n o r a l s t a t e m e n t m a d e t o t h e C h a i r m a n


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Federal Reserve Bank of St. Louis

19
and Governor,
Now,

by &

a n d t h a t w a s t h e p r a c t i c e f o r s o m e years.

gradual p r o c e s s

o f inching

o n them,

w e have

finally g o t written statements, a n d n o bill tis purchased
by t h e F e d e r a l R e s e r v e B a n k i n N e w Y o r k t h e t i s n o t b a s e d

upon consideration o f a written statement, w h i c h i s i n a
special b o x accessible t o only two o r three officers o f
the bank, a n d t h a t w r i t t e n statement,

as a

rule, w h e n i t

is filed with us, i s handed t o the Governor o r Chairman,
or both,

b y a partner

i n t h e firm, a n d t h e n w e a s k several]

questions about t h e statement, a n d anything material i s

dealt with i n a little separate memorandum that the officer
makes,

a n d except w e could handle t h e matter

i n that w a y

we w o u l d g e t t h e statements.

Governor Fancher. Isn't i t a fect that, with the
exception o f J. P. Morgan & Company, a l l o f the private
banking concerns whose paper i s accepted, h a v e stixtements o n file with the other banks?
The Chairman. T h a t m a y be.
Governor Fancher,

Tne Chairman. I

I t i s a n o u t s t a n d i n g exception.

doe not know what t o d o about that.

Gentlemen, t h e Board i s waiting f o r me.
(Whereupon, oat 1 1 o'clock a.m., a

recess w a s taken


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Federal Reserve Bank of St. Louis

20

until 1.49 p.m., w h e n t h e following occurred) :
The Chairman. Gentlemen, suppose w e adjourn f o r
lunch n o w a n d return a t 2 olclock sherp.
isfactory? T h e r e being n o objection,

I s that sat-«

w e will adjourn

until & o'clock.
(Whereupon,
until 2

a t 12.50 p . m , a

re

otclock p.m.)

AFTER RECESS.
The C o n f e r e n c e w a s r e s u m e d a t 2

o'clock pem.,

a t the

expiration o f the recess,

The Chairman.

W e were discussing the question o f

the statements o f subsidiaries, before t h e interruption
of t h e o t h e r meeting,

and I

think Mr. G e e r y w a s f i n i s h -

ing h i s statement.
Governor Geery.

N o .

I t w a s s u g g e s t e d t h a t t o furn-

ish those statements t o the member banks a n d they furnish
them i n turn t o the Federal reserve bank, t h a t would
cover t h e whole situation.

H e does n o t want t o have t o

furnish them t o every Tom, D i c k a n d Harry.
Governor Bailey.

H o w would a

broker h a n d l e t h a t ?


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Federal Reserve Bank of St. Louis

ve
Would h e have a

lot o f them made a n d furnish o n e every

time h e sent a note t o the Federal Reserve B a n k f o r discount?

Governor Gerry.

No, I

do not think that would b e

required, provided the depositary banks did and the
Federal Reserve B a n k h a d i t from them.

The Chairman. O f course, there i s that point that i f
we check u p every bank that offers paper’. t o u s t o see
that t h e regulations a r e literally complied with i n every
particular, y o u will find some banks that have n o t statements o f the subsidiaries. I

do not think w e d o i t t o

that extent i n New York.
Governor Bailey.

I f w e had t h e reports o f the subsidiar-

jes, couldn't w e copy t h e reports a n d furnish them?

Governor McDougal.

Y o u would have a hard job i n

copying it.

The Chairman. Governor Harding, h o w does i t strike
you, t h i s q u e s t i o n ?

Y o u have that question u p i n New

England, with the mills subsidiaries.
Governor Harding.

M y idea i s that i t i s a goad deal

more important t o get paper that i s going t o be paid,


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Federal Reserve Bank of St. Louis

oe
butII c a n see from t h e standpoint o f these concerns
that have subsidiaries t h a t t h e y might have v e r y good
grounds f o r objecting t o having these statements scattered around i n the hands o f a miscellaneous l o t o f
bankers a n d brokers.

I t might p u t t h e m i n bad from a

competitive standpoint. I

also a p p r e c i a t e t h e p o i n t

that t h e F e d e r a l R e s e r v e B a n k d o e s n o t w a n t t o p u t i t -

self i n the position o f passing o n the credit o f a member
bank.

B u t i t seems t o m e that a l l o f the requirements

of the situation would b e met i f the corporation depeositell
with i t s p r i n e i p a l . d e p o s i t o r s a

then w

h

consolidated statement,

e : nybroker's
n: a
paper came i n and they wanted ‘to

check that paper up, t h e y would d o a s they d o now a n d
write t o their correspondents:

" W h a t d o y o u know about

this paper?” T h e n let the corporation deposit with the
Federal r e s e r v e b a n k o f i t s district,

w i t h t h e understand-

ing that copies will b e sent t o all other Federal reserve
banks, t h e consolidated statement a n d t h e statement o f the
subsidiary.

N i n e t y nine times o u t o f a

hundred a

bank

extending credit t o a corporation gets a l l t h e information
it wants f r o m t h e consolidated statement,
and I

i n m y judgment,

think t h a t w o u l d m e e t a l l o f t h e requireménts.

L e t

the F e d e r a l R e s e r v e B a n k h a v e t h e c o n s o l i d a t e d s t a t e m e n t


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Federal Reserve Bank of St. Louis

23
and t h e s t a t e m e n t s

o f t h e subsidiaries,

principal d e p o s i t a r y b a n k s

a n d let the

o f the corporation h a v e t h e

consolidated statement.

Governor Geery.

B u t not t h e subsidiaries?

Governor Harding. N o , sir.
Gevernor Fancher.

T h a t seems

t o be a

point w h i c h

the d e p o s i t a r y b a n k s a r e raising, t h a t t h e c o r p o r a t i o n s
furnish t h e i r s t a t e m e n t s
furnish t h e statements

t o t h e Federal teserve banks a n d

o f t h e subsidiary corporations,

simply t h e c o n s o l i d a t e d s t a t e m e n t

i n s o m e cases,

and

a n d the

bank would like t o have t h e subsidiaries! statements a n d
sometimes t h e y get i t and sometimes t h e y d o not g e t it,

and I think the depositary bank would like t o have all
that i s furnish ° ‘ the Federal reserve bank. I

think that

is a point that these b i g corporations make, t h a t t h e y
furnished t h e consolidated statement t o the Federal reserve
bank a n d the statement o f the subsidiaries, a n d have o n l y
given t h e depositary b a n k the consolidated statement.
Governor Harding.

to give a

I

f y o u require t h e corporations

detailed statement t o two o r three o f the larger

depositary banks, t h e other banks h a v e t h e same right t o
ask f o r i t , b u t y o u c o m e r i g h t b a c k t o t h e s a m e p r o p o -


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Federal Reserve Bank of St. Louis

24
sition, t h a t t h e y h a v e t o g i v e t h e i r w h o l e b u s i n e s s

to

the public.

Governor Geery. G o v e r n o r Harding's statement i s
just what t h e Washburn-Crosby Company has b e e n doing.
They furnish t h e depositary b a n k with the consolidated

statement a n d the Federal reserve bank with both.
Governor Fancher.

A n d y o u find i n some cases t h a t

the depositary b a n k would like t o have t h e subsidiary
statements?
Governor Harding.

T h e depositary b a n k c a n get what

they w a n t b y a s k i n g s o m e p o l i t e questions.

T h e y c a n say,

"We have g o t your consolidated statement a n d w e would

like t o know something i n addition.”
Governor Seay.

I t seems t o me, Mr. Chairman, t h a t

the regulation a s i t stands i s a good o n e a n the side
of s a f e t y a n d f o r t h e p r o t e c t i o n o f t h e F e d e r a l r e s e r v e

bank.

I t also seems t o m e that i f these corporations d e -

sire t o float their paper i n the country generally, t h a t
at l e a s t t h e i r d e p o s i t a r y b a n k s o u g h t t o h a v e t h e f u l l

statement, t h e consolidated statement a n d t h e statement
of the subsidiaries o f the corporation; b u t i t does n o t
seem t o m e t o b e s o necessary f o r these small interior


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Federal Reserve Bank of St. Louis

25
banks t o have this information, provideq t h e y have t h e
consolidated statement.
tary bank, I

B u t , w i t h respect t o the deposi-~-

believe t h a t u n c o n t e s t a b l y t h e y o u g h t t o

have those statements.
The Chairman.

T h e y generally have a

line o f credit

there.
Governor Seay.

I believe,

A n d w h i l e i t w o u l d n o t b e well,

t o make a n y exception i n the matter,

as

w e all

know that practices g r e w u p i n handling these things

which are summed u p i n the regulation. I

do not believe

it t o b e a n y infringement u p e n t h e p r i n c i p l e

t o take

paper f r o m these small interior banks, w h i c h have n o t

got these statements o f the subsidiary companies a n d
which w o u l d n o t k n o w e x a c t l y h o w t o protect t h e c r e d i t i f

they h a d them~-I think w e might ignore i t provided t h e y

have the consolidated statement; but I believe i t would
be g o i n g i n t h e w r o n g d i r e c t i o n

t o undertake

t o alter

the regulation.

Governor Bailey. Supposing a bank offers you a
$5,000 note, a country bank who has bought this through
a broker, a n d the broker says "This i s checked b y two
or three banks, which are depositary banks."

W e write

them and they give u s the proper credit information; t h e y


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Federal Reserve Bank of St. Louis

2¢@
discount this note, after having carried i t for sixty
days, f o r anotheY thirty days.

W h a t weuld y o u a s k them

about that? W o u l d y o u a s k them i f they have a l l o f
these statements?
Governor Seay.

M y own opinion i s that t h e y should

have t h e consolidated statement.
Governor Bailey. T h e n t h e brokers would have t o have

Governor Seay. Yes, I
be e n c o u r a g e d

think so, a n d they cught t o

t o have i t , too.

I

f they invest their

money t h e y o u g h t t o invest t h e i r m o n e y i n t e l l i g e n t l y a n d

with information a t hand a n d ought n o t t o depend u p o n t h e
Federal reserve system when t h e y send i t direct.

I f

they sell that paper t o their banking correspondents, a l l
well a n d good; b u t i f they take i t t o the Federal reserve
bank for a rediscount, t h e n I think t h e y ought t o b e
in a position o f not having t h e Federal reserve b a n k t o
pass u p o n it, b u t pass u p o n i t themselves b y reason o f

holding the statement.
Governor Fancher. W i t h o u t a n y discount a n d purchase
of the paper f r o m the small interior bank, i f t n offering that t h e y d o not s a y that t h e y have a statement,


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Federal Reserve Bank of St. Louis

aa
and w e have a statement w h i c h comes f r o m other sources,
we a d v i s e t h e b a n k t h a t i t i s i n c u m b e n t
ing p a p e r t o h a v e a

statement,

furnish a statement. I

o n t h e m i n buy-

t h a t t h e broker should

am quite i n accord with the

view expressed here b y the Federal Advisory Council

that the depositary bank should b e furnished with not
only the congolidated statement, b u t a statement f r o m
the subsidiaries, a n d w e might g o further, a n d s a y that
brokers i n all cases furnish a consolidated statement
to the bank that purchases t h e note.
The Chairman.

W

e cannot discount t h e paper unless

the member b a n k which has purchased t h e paper a n d submits
it s h o w s

i n the application that t h e y have a

Governor Fancher. A
The Chafrman,

statement.

statement.

W e d o not mean t e exemine them, b u t

we take their word for it,
Governor Fancher. Sure.
The C h a i r m a n . I

understand a

motion h a s b e e n m a d e t h a t

the policy should b e t o require these corporations t o file
a consolidated statement a n d statements

o f their subsid-

laries w i t h their depositary bank, w h i c h shall b e furnished
to the Federal Reserve Board b y the depositary bank.


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Federal Reserve Bank of St. Louis

28
Governor ticDeugal.

M y suggestion w a s t h e w o r d

“principal” b e inserted before the words "depositary
bank."
The Chairman. Yes.
Governor Seay. I

hope that Governor McDougal will

withdraw t h a t , b e c a u s e h o w c a n y o u m a k e t h e e x c e p t i o n

consistently a n d logically?
Governor sicDougal. I

can answer thet, Mr. Chairman,

by s t a t i n g t h a t s o m e o f t h e s e c o r p o r a t i o n s o p e n perhaps
innumerable a c c o u n t s f o r c o l l e c t i o n purposes,

with the

understanding t h a t t h e y will b e remitted f o r twice a week
or something l i k e that, a n d that t h e y a r e purely collectfon accounts, a n d I

do not think that these banks should

be considered i n the light o f depositary banks.
Governor Seay. G o v e r n o r McDougal,
has s t a t e d t h e matter,

a s Governor S t r o n g -

w e could n e t handle t h e paper o f

these corporations f r a m a n y one o f their depositary banks
unless t h e depositary b a n k h a d statements.

S o , A t ‘per

chance t h e y s h o u l d f i l e t h o s e s t a t e m e n t s o n l y w i t h t h e

principal b a n k a n d yet some other o f their depositary
benks sheuld b u y the paper, t h e y could n o t redepesit i t
with t h e F e d e r a l r e s e r v e b a n k u n l e s s t h e y h a d t h e s t a t e ment.


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Federal Reserve Bank of St. Louis

29
Governor ilcDougal.

T h e y would have a statement o f

the borrower,

I t might b e t h e corporation operating

subsidiarjes,

o r i t might b e one o f the subsidiaries

which wonedewned b y that corporation.

T h e y would have

a statement o f that sort, b u t t h e y could not b e expected
to have this vast amount o f data a n d other information
that a c c o m p a n i e s t h e s e c o n s o l i d a t e d s t a t e m e n t s , w h i c h r e -

quires careful examination b y your o w n expert credit m e n
in order t o analyze a n d understand t h e situation.
Governor Fancher.

W h y cannot t h e situation b e cov-

ered by "depositary banks which grant lines o f credit?"
The Chairman.

T h a t w o u l d d o itt.

Governor Seay. That i s the point I had i n mind, because a n y other bank would have t o get t h e statement,

The Chairman.

W i t h depositary banks which grant a

line. of: credit?
Governor Fancher.

T h a t covers i t , a n d I

second t h a t

motion.

(The motion was put and carried.)
The Chairman. I

will a s k Mr. Harrison t o distribute

the. report which has just been made t o the Federal Reserve Board b y the Open Market Committee. That. 1 s Topic


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Federal Reserve Bank of St. Louis

14“A o n the progratn.
l, C r e d i t Transactions a n d Policies.
A. O p e n M a r k e t Operations.

1. R e p o r t o f Vpen Market Investment
Committee.
Canc P O L E «

(The Secretary distributed t h e report referred to.)
The Chairman (continuing).

T h a t should have b e e n

marked "Confidential, " o f course,

were. I

a s t h e other papers

would like t o explain that i t was expected

that t h e meeting o f the O p e n Market Committee would b e
held t w o w e e k s

o r m o r e e a r l i e r t h a n i t w a s held,

but

the r e p o r t s t h a t w e r e d i s t r i b u t e d y e s t e r d a y o r t h i s

morning were prepared some time ago, a n d they have
brought d o w n t o d a t e s u c h report,

a n d w e anticipated,

as the d a y o f the meeting h a d been deferred, t h a t w e
would meet w i t h the Federal Reserve Board yesterday

afternoon and that the whole precedure would b e i n the
usual course o f the meeting o f the Open Market Committee

with the Board i n between the dates of the Governors!
meeting,

b u t t h e Secretary w a s detained a t t h e Capitol

yesterday,

a n d w e c o u l d n o t m e e t i n t h e afternoon,

s o

we had t o have the meeting this morning, a n d i t would have
taken s c l o n g p r o b a b l y t o h a v e c o n s i d e r e d t h e r e p o r t a t


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Federal Reserve Bank of St. Louis

Sk

this meeting that w e had t o go right ahead with the
meeting a n d leave t h e Governors! Conference, a n d these
recommendations w h i c h a r e n o w b e f e r e y o u w e r e d i s c u s s e d

a couple o f hours this morning, a n d efter w e left t h e
Board m e t a n d I now have this communication f r a m Governor
Young:

Mr. Harrison (reading):
"My dear Governor Strong;
"At the meeting o f the Federal Reserve B o a r d held
todey following t h e conference w i t h t h e members o f your

committee, during which the revert o f the committee,
deted November 1 , 1927, w e s submitted tothe Soand a n d
discussed i n detail,

i t was voted b y the Boerd that

epproval b e given t o the policy governing o p e n morket
operations a s recommended b y your committee i n its report

referred to.
Very truly yours,
(Sed )

A o .

Youre.

Mr. Penjemin Strong,

Chairmen Open Market Investment Committee.”


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Federal Reserve Bank of St. Louis

32
The Chairman.

Y o u m a y o r m a y n o t h a v e h a d oppor-

tunity t o read the memoranda submitted this morning.
This report i s the report based upon those memoranda
which has n o w been apvroved b y the Federal Reserve Board,
and i t will g o forward i n the regular course t o the
Federal reserve banks w i t h t h e usual letter f r o m the
Chairman o f the Open Market Committee f o r consideration
by the respective boards o f directors o f the Federal r e serve bank, a n d this i s the opportunity t o distussuit,
if there a r e questions w h i c h are obscure, a n d all t h e
committee a r e here t o answer questions.
Governor Talley.

M r . Chairman, I

want t o s a y the

tentative d a t e o f March l s t would b e t h e latest d a t e
that w e would like t o approve of.
The Chairman.

T h e r e was a reason f o r putting that

date in, because this report h a s a

gnod deal o f flexi-

bility, a s y o u c a n see from its terms, a n d b y tentatively,
subject t o review i f occasion reguires, spanning t h e
period t o March lst, i t takes c a r e o f all o f the unusual
operations t h a t arise around t h e e n d o f the year a n d
the beginning c f the next year, a n d w e should hope that
after M a r c h l s t w e w o u l d s a i l o f f i n t o s m o o t h w a t e r s


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Federal Reserve Bank of St. Louis

33
without m u c h t o do.

A t a n y rate, j u s t p r i o r t o M a r c h

ist, i f w e have another committee meeting, w h i c h w e

likely would possibly do before that, we will mow a
good deal more about developments t h a n w e n o w know.
February l s t w o u l d h a v e b e e n e

little t o o soon, a n d

after consideration i t seemed a s though March l s t was a
conservative date.
Governor Talley.

M a r c h l s t i s quite a n agreeable

date f o r us.

The Chairman.

I t also fixes u p the program s o that

before t h e March 1 5 Treasury financing w e c a n have an-.
other meeting a n d consider everything again.
Governor S e a y . I

natice

i n the opening paragraph

you say "Main Far bie rates for money at about present
levels."

Y o u mean, I suppese, b y the word "about,"~-

The Chairman. (interposing). Oh, yes. Y o u know the
money market i s more o r less u p a n d down. I

should hope

that there would not b e any material change i n the rates
for commercial paper, bankers! acceptances a n d the ordinary line o f time a n d commercial loans. I

d o not care

so much about t h e call rate o n the stock exchange; t h a t
goes u p and down, b u t i t takes a

little period o f higher


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Federal Reserve Bank of St. Louis

34
or lower money o n the call l o a n market f o r the other
rates t o respond t o it, a n d I

do not think the fluct-

uations within moderation i n the call l o a n rate would
be important i n the policy expressed there,

s o long a s

it did not last t o o long.
Governor Seay. T h e point that I

have particularly

in mind refers t o the reserve rate itself. I

presume

you meant a t o r about t h e present levels.
The Chairman. Yes. T h i s does n o t refer t o reserve
bank d i s c o u n t r a t e s .

T p n i s refers

t o market rates.

Governor S e a y . Y e s , b u t t h a t i s affected,

w e think,

to some extent b y the Federal reserve b a n k discount
rates.

The Chairman.

A l l right.

I f any occasion came t o

change o u r d i s c o u n t r a t e i n N e w York,

it without having a

w e would n o t d o

meeting w i t h t h e cormittee o r con-

sulting with the committee.
Governor S e a y .

T h e present discount rate,

o f course,

is below what y o u would call t h e general credit market.
The Chairman.

N o mere t h a n usual.

Governor Seay. T h e discount r a t e i s not?
The Chairman.

N o t i n N e w York.


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Federal Reserve Bank of St. Louis

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Gevernor Seay.

I t i s below t h e commercial rate, o f

course?

The Chairman.

I t always ts.

Governor Seay.

I t i s a little b i t lower i n propor-

tion than customary?
The Chairman.

No.

T h e commercial paper rate i s 4

or a shade over- [ f t is about t h e same.

Gevernor NcDougal. A

shade under toe.

The Chairman. Yes. S o m e o f the best commercial
papers shade a little less t h e n 4 per cent.

Governor Geery. I n our district i t i s 4-3/4.
The Chairman. I

think t h e d i f f e r c n t i a l b e t w e e n o u r

rate and the going rate fot commercial leans i s Just
about t h e s a m e a s 4 t w a s s h o r t l y p e f o r e w e r e d u c e d o u r
rate,

Gevernon Seay.

I n other words, y o u mean that t h e

commercfol r a t e h a s b e e n l o w e r j u s t a b o u t

i n proportion

with the Federal reserve b a n k discount rate i n your mare
ket?
The Chairman. Yes,
Gevernor Fancher.
for s h o r t - t i m e b i l l s ?

A n d the rate i s about 3

per cent


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The Chairman. T h e relationship o f the rates h a s b e e n
maintained

b y the reduction

paper which has a

i n market r a t e b y t h e g o i n g

market rate j u s t about t h e same re-

lationship t o o u r l o w e r r a t e a s i t h a d t o t h e 4

rate.

per c e n t

W h e n w e h a d a 4 per cent discount rate t h e very

best commercial paper was selling about 4 4 or a little
above.

O f course, I

a m speaking o f New York especially.

Now, i t i s selling a t 4 and sometimes t h e very best paper
a little above.
Gevernor Wellborn.
agricultural banks,

W h a t i s the theught about t h e

o r banks located i n agricultural sect-

ions, increasing their rate before t h e borrowings b e g i n
next spring o r early i n the year?

The Chairman.

W e have not discussed that a t all,

Geverner Wellborn.
Gevernor Wellborn.

W e have n o t noticed i t yet be-

cause t h e time has n o t arrived a n d t h e market h a s n o t
been affected a t the present time.

B u t I have heurd

several bankers s a y " I can g o out a n d b u y some bonds a t

4 per cent and rediscount them at 3%." S o they have
been thinking along those lines o f making some profit
out o f t h i s v e r y l o w rate.


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Gevernor Fancher.

D o y o u think they are doing

Governor Wellborn.

N o , n o t t o any apvreciable

that?

extent.

U u r loans are down.

W e have had s o many

banks t o liquidate their indebtedness fin full this year
that o u r loans a r e down.
Governor Seay.

T h e y a r e investing a

considerable

p o r t i o nf
o their funds i n readily: marketable bonds i n

our district, a n d I think they have their eye o n the
Federal -reserve rediscount rate.
create a

T h e i r object i s t o

secondary reserve.

The Chairman.

B u t they are not doing that o n the

money they borrow from you?
Governor: Seay. N o .

Governor Wellborn. T h e y are doing that from their
honeuske w h e n t h e proceeds o f the crops have b e e n sold,

but a s soon as those deposits begin t e melt away and
go out into agriculture again, t h e y will want t e borrow
meney o r sell t h e bonds.
The Chairman. Haven't t h e y always done that more
or less?
Governor Wellborn. T h e tendency seems t o b e growing


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in that respect, about buying bonds.
Gevernor Fancher.

I s n ' t that d u e t o the lack o f

desirable bills s o l d b y brokers a t the present time?
Governor Wellborn. I
causes.
loans,

think i t i s due t o several

I t i s easier t o handle bonds t h a n t o handle
o r t o g o o u t a n d s e e k loans;

may not b e considered s o good.

o r t o take loans

I t i s along t h e line

least resistance, y o u might say.
Governor Seay. T h e r e i s this eventuality, t h a t having
these excess funds i n bonds returning 4

per cent, t h e

probability i s that when the occasion comes f o r t h e m t o
borrow,

i f they c a n borrow f r o m u s a t 3 g per cent, t h e y

will borrow 3

o n the bonds.

Governor McDougal. Mr. Chairman, I

have n o t under-

stood a n d d o not understand that t h e adoption o f this
plan would necessarily bind a l l o f the banks o r commit
them t o a

3% per cent discount r a t e f o r t h e next f o u r

months, a n d I

do not think that w a s t h e intention.

The Chairman. N o .

I t i s not mentioned i n the report.

Governor McDougal.

B u t that question w a s raised b y

Mr. Seay, a n d that was m y understanding.
Governor Seay. I

do not think i t was implied i n


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there that a n y Federal reserve b a n k would take t h e position o f s a y i n g t h a t i t w o u l d v o t e f o r p r e s e r v i n g i t s o w n

3g per cent rediscount rate, because w e would not b e
willing t o take that position.
The Chairman.

W e would not, either.

Governor Fancher.

T h e rate f o r money means t h e com-

mercial rate and has n o bearing o n the Federal reserve
bank rate.
The Chairman.

T h e r e fis a saving c l a u s e

i n the report

right a t the beginning that conditions m a y change which
will necessitate a
had n o thought,

review o f the matter. T h e committee

b y direct commitment o r implication,

to

bind itself o r any bank t o retain t h e present rediscount

rate. Y o u could net d o it, any way, i f you wanted to.
Are there a n y other questions?
Governor Seay. I

have n o further questions, w i t h the

understanding, Mr. Chairman, a s I understand y o u t o set
forth, that the fixing o f the first day o f March i s simply
an a r b i t r a r y fixing,

a n d that t h e whole policy o f the

committee

investments
i
/ subject t o change o n account o f changing
conditions.
The Chairman. Y e s .


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Governor Seay. W h i c h I

ef course would take f o r

granted.
The Chairman.

W e had a period o f three a n d one

half months before, I
until August Ist.

think i t was, o n the last approval,

W e met o n Way Oth, a n d that i s about

three months, a n d this makes i t four months.
Governor Seay. P e r s o n a l l y I

think that part o f the

interior w i t h w h i c h w e a r e c o n c e r n e d

py the 3 4 per cent rate. I

i s :not b e n e f i t t e d

think i t i s too low a rate,

and I thought s o from the beginning, b u t that h a s n o bear~
ing upon t h e general policy o f the Investment Committee
from t h e point o f view that i s presented there. I

think

it 4 s rather harmful t h a n otherwise.

The Chairman. Y o u think i t is rather harmful?
Governor Seay. Yes, sir.

T h e interior which i s

accustomed t o lend i t s money a t rates which a r e much
higher t h a n those prevailing i n the money centers,

is

getting a false perspective.
Governor Bailey.

D o y o u mean t o s a y that t h e country

banker finds fault because this rate is lower; that his
customer

asks

h i m t o lower h i s rate

t o him

o n that a c -


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count?

I s that i t ?

Governor Seay. N e . I think i t is giving him a
false perspective o f the condition o f money i n his o w n
locality a n d i n t h e d i s t r i c t w h i c h t h e F e d e r a l r e s e r v e

bank serves.

N o matter what h i s customer m a y desire

or ask him, h e i s going t c lend his meney t c him at the
best rate h e c a n get, a n d i s usually i n a position t e
enforce a n y r a t e h e asks.

Governor Talley.

D o you find that t h e best borrow-

ers i n y o u r d i s t r i c t h a v e a c c e s s

t o t h e competitive r a t e

for m o n e y ?

Governor Seay. A l w a y s and a t all times.
Governor Talley. I

think that money i s worth about

the same t h e world over, a s a rental charge.
Governor Seay. T h e benefit o f the lower rate reaches
the b e s t borrowers,

w h o have access

t o competitive m a r -

kets,
The Chairman.

T h a t h a s some favorable effect a t

times t o have that condition arise, d o e s i t not?

Governor Seay. Yes.

I t is hard t a define i n per-

centages, b u t i t has some kind o f effect. W h e t h e r t h e
result o f that effect i s beneficial o r otherwise usually


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has t e b e proved

b y the future.

The Chairman. I

mean y o u r c a n n e r s d o w n t h e r e w h o

buy the food a n d vegetable crop, s o m e o f them have accounts i n New York, Philadelphia,

o r other cities, a n d

when t h e discount r a t e goes d o w n they borrow their money
a Little cheaper.

D i r e c t l y and i n a

remete w a y t h a t

benefits t h e fruit a n d vegetable growers?
Governor Seay.
The Chairman.

I t may o r may not; t h a t i s the point.
I t does n o t hurt t h e m any, d o e s i t ?

Governor Seay. E x c e p t i n the vague w a y i n which I
have endeavered t o give expression. I
deadens t h e m t o a

think i t scmewhat

truse s e n s e o f t h e p r e s e n t d e g r e e o f

expansion, w h i c h i s rather large, s a y what y o u will.
Governor Talley.

T h a t i s what i s happening i n our

district right a t the present time.

T h e exports o f cotton

ere lower t h a n they were last year.
The Chairman.

I n t h e n u m b e r o f bales?

Governor Talley. Y e s ,

i n t h e n u n b e r o f bales,

and

the cotton i s being purchased a n d i s going into merchants!
stock, a n d i n the last t w o weeks o u r loans have increased
about $9,000,000 f r o m the l o w point, a n d the applications
come f r o m banks w h o a r e carrying large stocks o f cotton


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for cotton merchants, a n d they a r e buying i t because
they c a n g o into stocks o n a lower rate.
The Chairman. T h a t m a y b e a good thing f o r your
cotton g r o w e r s d o w n there,
Governor Wellborn.
growers v e r y much.

I t helps t h e dealers.

Governor Talley.
basis.

I t does n o t h e l p t h e c o t t o n

I t simply avoids the depreciation

I t helds t h e b a s i s u p .

Gevernor Seay. H e is able t o market his c o t t o n t
a

good prices, if he has any idea whatever, a s most of
them have, t h a t prices m a y increase;

a n d t h e carrying

charges a r e lower,
Governor Talley.

Y o u c a n take t h e l a t e ginnings

which come o n the market, and that does not affect the
basis m o r e t h a n f i f t e e n o r t w e n t y peints,

a n d when that

ginning report came out you had a little upturn i n the
prices right away.
Governor Seay. T h a t s h i f t s t h e r i s k f r o m

t h e buyers

or holders o f cotton.
Governor Talley.

O h , yes.

H o w m u c h better t h a t t s

from a n economic standpoint f o r t h e stocks t o g c into
the hands o f the merchants w h o are willing t e absorb


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46
them, a n d the producer i s willing t o sell a t prevailing
prices.

M t talsssc t h e speculative elemént o u t o f it.

The Chairman. Y o u think i t i s a benefit i n your
district?
Governor Talley.

a benefit, b u t I

E

y think t h a t atbothis t i m e i t 1 s

do not think w e c a n s a y arbitrarily

that e v e r y f a l l w e s h e u l d l o w e r t h e r e d i s c o u n t r a t e a t

the Federal reserve b a n k because that depends o n the
circumstances.

C e r t a i n l y these same circumstances t h a t

we have prevailing i n our district this year d i d not
prevail l a s t year, b e c s u s e e v e r y f a c t o r t h a t p e i n t e d

a liquidation o f the indebtedness w a s ecbscure. §

to

This

year i t i s entirely patent, a n d while t h e factors a r e
operating.
Governor Wellborn. S p e a k i n g o f this year a s compared w i t h l a s t year, t h i s l o w r a t e w o u l d h a v e b e e n
more b e n e f i c i a l l a s t y e a r t h a n t h i s year.

T h e holding

of movement then was i n its inception.
Governor Seay.

Y o u see, t h e r e a r e t w o o p p e s i n g

views f r o m different districts, t h e Texas a n d t h e Atlanta
view.
Governor Talley. I

do not agree t o that.


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Governor Seay.

T h a t would have been t h e time f o r

us t o have lowered it, because w e had a tremendous c r o p
on hand a n d were n o t disposed t o sell it, a n d this year
they w e r e s a t i s f i e d w i t h t h e p r i c e a n d s o l d i t v e r y

readily.

The Chairman.

W e grew 15,000,000 bales o f cotton

last year a n d exported a

little o v e r 11,000,000.

N o w

the crop this year i s about 13,000,000, with not quite
double t h e price, a n d t h e question is, w i t h 6 0 per cent
of cur cotton last year o r more t h a n 6 0 per cent ordinarily going abroad, a r e w e going t o b e able t o export
the preportion o f this year's c r o p that w e should.

If

there i s any delay i n buying i t abroad for any reason
obtaining over there--because t h e y stocked u p o n cheap

cotton last year o r because money i s dear there, o r for
any ether reason,--then i t i s just a s well t o have some
cheap m o n e y t e c a r r y t h a t c e t t o n a t t h e p r e s e n t time.

Gavernor Wellborn. A t the present time.
The Chairman. Yes.
Governor Wellborn. I
cuts a n y figure.

do not know that half a

per cent

T h e thing thet affects people i s that

when y o u raise i t a little. L o w e r i n g i t dees n o t s e e m


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to affect t h e m much, b u t when y o u raise your rate i t
startles p e o p l e .

later.

W

e a r e beund t e raise o u r rates

W h e n this rate w a s reduced w e had n o idea o f

wanting a n y reduced rate a t all.

W e have been com-

pelled t c d o i t because Kansas C i t y a n d St.Louis a n d
Dallas h a d put theirs i n effect, a n d they a r e next door
to us.

The Chairman. Governor Baitey, h o w d a y o u feel
about t h i s r a t e c h a n g e ?

Governor Bailey. I

would like t o see t h e rate g o

back t o 4 per cent some time this winter.

T h e thing

that h a s h e l d i t u p i s this wonderful c r o p movement.
The Chairman. Except maybe t h e cotton m a y b e late.
It i s late t o some extent now.

T h e movement o f cotton

that h a s moved s o far this year represents m o r e money
than t h e corresponding date last year, o n account o f the
price.
Governor Talley.

A n d i t puts t h e banks

i n a n easier

position.
The Chatrmari. Yes. T h e cotton erep this year was a
problem because o f the possible hang-over f r o m last
year's v e r y large c r o p i n bulk,


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Governor Talley. T h e movement o f sterling alsc has
a close r e l a t i o n t o t h e c a t t o n movement.

The Chairman. Y o u think that h a s helped t h e sale o f
cotton?

Governor Talley. Gh, yes.
The Chairman. I

about that.

have h e a r d s o m e d o u b t e x p r e s s e d

W i l l y o u elaborate that a little bit?

Governor Talley. I have a brother i n law who has
charge o f a certain firms b u s i n e s s west o f the Mississtppi River, a n d I visited w i t h h i m last Sunday i n Houston,

and he said this price o f sterling had not been a matter
of consideration a t all; h e would simply g o ahead a n d

sell his sterling a t a profitable price.
The Chairman.

I t did not worry him?

Governor Talley. I t did net worry him a bit. I said,
"That i s something t h e Federal Reserve System i s doing

for you that you d e not know about,” and that o f course
has b e e n t h e case a l l over t h e district.

I n other words,

the cotton merchant, t h e cotton exporter, h a s b e e n able
to operate this fall with more assurance t h a n h e has within the last five years.

T h a t i s t h e w a y h e gets his

reimbursement o u t o f a large part o f his exports. The


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higher price h e gets for his sterling the moré points
he has got i n his transaction.
“Governor Seay. T h a t i s true o n a rising sterling
wereck:
The Chairman.

I t does h e l p t h e export o f cotton,

doesn't i t ?
Governer Talley. 1 6 8 .

The Chairman, Governor Bailey, h o w d o you feel about

the effect of the rate r e d u c t i otuno
in your district?
Governor Bailey. O u r people K a s accepted i t all
right, a n d teok i t i n the spirit tnat i t was broadcasted,
and the cattle m e n are getting their money f r o m a haif t a
one p e r oént cheapes this y e a r than last year.

O n e of

the big banks sent out a letter saying that f n view of
the fact thet t e e Federal reserve b a n k h a d reduced

its rediscount rate, i t made that. bank's rate cheaper,

I will say, i n view of that, that their rates have been.
too high always.
Governor Seay. What. are they, f o r instance--8 p e r
cont?

dovernor Bailey. N o t now.
Governor Seay- They have been?


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Governor Bailey.

I t was 8

per c e n t r i g h t d u r i n g

the hard times after t h e war.

Governor Seay. A n d what i s i t now? 73?
Governor Bailey.

No.

I t i s from 6.to % .

I t 4s

the first time I ever saw a letter g o out saying, " I n
view o f the fact that t h e Federal reserve b a n k has reduced
its rate w e will have a n enlargoment o f the heart a n d

follow suite."
The Chairman,

A r e there a n y more questions about

the report o f the Open Market Committee? T h i s having
been a meeting theoretically i n between the Conference

of the Governors, i t would not ordinarily be approved b y
the meeting b u t would b e submitted i n detail t o each reserve bank, b u t i f y o u wish t o act o n the report i n any
way a motion would b e i n order.

Governor Biggs. I

move the report b e accepted and

filed.
Governor Talley. I
The Chairman.

second it.

I s there a n y debate o n the motion? A r e

you r e a d y f o r t h e q u e s t i o n ?

(The motion was put and unanimously carried.)
The Chairman.(continuing).

T h i s will really cover


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Topics 1

and 2 under A .

N o . 3 is--~

Discussion o f method o f appértioning
bills a n d Government securities bought
by O p e n M a r k e t I n v e s t m e n t Committee.

I have asked Mr. Case t o prepare a little memorandum, a s h e does most o f this w o r k i n the bank, a n d I

do

not know but what i t would b e illuminating f o r Mr.
Harrison t o read it, i f h e will.

Mr. Harrison: Al] right:
"The method o f apportioning purchases made
by the Open Market Investment Committee o f bills
and Government securities during t h e past t w o
years h a s r e m a i n e d p r a c t i c a l l y unchanged.

During

the f i r s t h a l f o f e a c h c a l e n d a r y e a r a l l p u r c h a s e s

made a r e distributed prorata ( 1 , e., i n the proportion that t h e total o f each bank's expenses,
dividends a n d chargeoffs bears t o the system total

of the same items) based o n the actual figures for
the preceding year.

"Beginning i n July i t is the practice t o obtain
from each bank a n estimate o f its probable income
for t n e b a l a n c e

o f the year classified according

sources, a l s o a n estimate o f its expenses, divi-

to


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Federal Reserve Bank of St. Louis

$3.

dends a n d probable chargeoffs.

T h e figures thus

obtained a r e combined with t h e actual results
shown f o r t h e y e a r t o date, t h e t o t a l r e p r e s e n t i n g
the e s t i m a t e d r e s u l t s f o r t h e year.

"The estimated surplus earnings o f the system,
if any, a r e then distributeg prorata a n d added t o
the estimated expenses, dividends a n d chargeoffs
of each bank, t h e total representing t h e gross earnings t o which i t i s considered e a c h bank i s entitled.
From this total there i s deducted t h e estimated earnings t o b e r e c e i v e d f r o m G o v e r n m e n t s e c u r i t i e s a n d
from b i l l s d i s c o u n t e d a n d miscellaneous,

t h e balance

thus representing the amount t o be earned from bills
purchased.

T h e ratio o f each bank's balance t o the

system t o t a l t s t h e n u s e d a s t h e b a s i s f o r d i s t r i b u -

ting current purchases o f bills.

"During the second half o f the calendar year
similar figures a r e prepared promptly after t h e close
of each month, a n d such changes a r e made i n the
ratio f o r distribution o f purchases a s the figures
justify.

O n this basis a l l banks a r e reasonably


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52

assured o f having e l l charges. provided for.and
also o f receiving a

fair share o f the excess earn-.

ings o f the systcom above charges,

i f any. T h e r e

is attached a statement showing the estimated results f o r t h e current y e a r { a s o f October e e 8

ie a

"In making the distribution of earning. assets
no c o n s i d e r a t i o n . h
a
s been given t o the condition

of the surplus accountsof the several banks, as.
to d o s o would conceivably affect t h e amount o f
franchise t a x t o b e p a i d b y t h e i n d i v t c u a l banks.

There i s attached a

statement showing t h e subscribed

capital a n d the surplus o f each bank a s o f December
51 f o r t h e l a s t f i v e years,

a n d also t h e ratio o f

subscribed capital t o surplus a s o f December 31,
1926.

I t will b e noted that there a r e four banks

which h a v e a

surplus e q u a l t o 1 0 0 p e r c e n t o f s u b -

scribed capital.

F i v e banks have surpluses ranging

from 9 3 t o 9 6 per cent o f subsoribed capital, while
three banks h a v e surpluses ranging f r o m 8 4 t o B86
per c e n t o f s u b s c r i b e d capital.

W i t h t h e exception

of Dailas e v e r y b a n k h a s a t s o m e t i m e h a d a

surplus

in excess o f 100 per cent o f subscribed capital.


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A study o f this statement w i l l s h o w that t h e
present u n e q u a l c o n d i t i o n o f surplus a c c o u n t s

i n

comparison w i t h s u b s c r i b e d c a p i t a l r e s u l t s m o r e

largely from changes i n the subscribed capital
account t h a n from inequalities

i n earnings,, those

banks whose subscribed capital h a s shown t h e largest
increase d u r i n g t h e p a s t f i v e y e a r s n o w h a v i n g

the smallest ratio o f surplus t o capital.

"On the whole it is believea the method which
has been followed i n distributing earning assets

has been fair and equitable t o all. banks."
The Chairman. T h e r e are a few points itn connection
with this that I

would like t o refer te,, 4 7 I may.

One

is the ratio i n New York o f surplus t o capital i s very
low c o m p a r e d t o m o s t o f t h e o t h e r r e s e r v e banks,. e n -

tirely due t o the fact that w e have h a d a large addition

to our capital through increase i n capital o f member
and

banks/in the organization of new banks i n New York.
On the other hand, Minneapolis presents the anomalous
situation of having a n excess of surplus because of
the m o r t a l i t y o f m e m b e r b a n k s a n d w i t h d r a w a l

subscriptions t o capital. I

o f their

do not s e e h o w the appor-


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tioning o f these earning assets, w h i c h roughly f o r m o n e
half o f the carning assets o f the System, c a n b e s o
affected a s t o c o r r e c t t h o s e inequalities.

I t would b e

a very difficult thing t o d o and probably would result
in injustice

i n other d i r e c t i o n s

o n t h e basis

o f earnings,

and Mr. Rounds, w h o has prepared these figures, h a s
talked t o m e about 1 t a number o f times, a n d h e assures
me that h e c a n devise n o plan o f cauculation that i s a n y
fairer t h a n this one, b u t that i f there a r e objections
to i t that w e are not aware of, w e would like very much
to hear them.
Governor Harding.

I f a n y bank has a reserve percent-

age down t o 5 0 per cent, t s i t a fair assumption t o make

that that bank 4 s paying its way and earning its. dividends
and expenses?
The Chairman. Yes, I

think so.

Governor Harding. T h a t being the case, i f a bank
has 4 reserve u p t o 5 0 per cent, w h a t i s the use o f giving
it a n y bills o r Government acceptances?

I f i t i s paying

its own way, w h y not eliminate from this distribution and
let i t catch u p o n its reserves?
The Chairman.

T h a t i s t h e c a s e w i t h FOU, 1 6 0 7 5 2 t ?


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Governor Harding. Yes.
The Chairman.

T h e earnings a r e higher a n d h e

is getting n o part o f the purchases.

Governor Wellborn.

H e has been eliminated from any

participation, because w e get the benefit o f the other
part

o f t h e year,

Governor Seay.

S o there i s n o parcicular i n which

that would not b e true, but there t 3 one particular I

think that memorandum is not correct in.

A s I recall,

it has been t h e practice f o r t h e past t w o years t o
make t h e a p p o r t i c n m e n t

o n t h e status

o f earnings f o r t h e

first three months, a h d they propose t o wait until the
half year t o uake t h e apportionment.

I f y o u look

back I think y o u will find that t h e apportionment h a s
been made o n the first quarter.

The Chairman. I

think this year and last i t has

been six months, a n d prior t o that i t was three.
Governor Seay.

T h e distribution w a s small i n our

Case, a n d t t did not provide f o r the requirements,

so

that i n the last half i t had t o be raised very consid-

erably. O u r reserve was reasonably high in the first apportionment, b u t our proportion was very large i n the


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second half, a n d i t sent o u r reserves low, a n d w e had t o
turn extrind a n d d i s p o s e o f a

considerable p r o p o r t i o n

of our securities w h i c h w e had been allotted. I

believe

it would b e better t o base i t o n the first guarter.
to the manner o f disposition, I
The Chairman.

A s

have n o criticism.

W e c a n d o that, b u t I must tell y o u

that o n e reason f o r changing t e the s t x months arrangement w a s because o f the immense amount o f work involved
in this thing. Y o u d o not realize h o w much work i t

takes with these shifting percentages, a n d i f your situation i s such that because o f the peculiar situation
in your district,

i f you will write u s a letter explain-

ing that w e c a n work this o u t a n d not have these changes
etcurlfor n i n e m o n t h s r i g h t t h r o u g h t h e year, w h i c h i s a
very f i n e j o b .

Governor Seay.

W e will d o that, o f course, a n d w e

would n o t have a n y idea o f asking that t h e method b e
changed t o fit t h e circumstances o f a n y particular bank.
As t o t h e amecunt o f w o r k i n v o l v e d I

was n o t a s w e l l

aware o f that a s you, o f course, b u t t h e distribution,
to b e made equitably during t h e year, should b e begun o n
the second quarter; b u t I

am disposed t o withhold that


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view.

The Chairman>

I t i s not soa much treuble w i t h

Governments, b u t when i t comes t o these bills w i t h all
the different denominations, w i t h all kinds o f names-and some o f the banks will take some names a n d some wont--

it is a Chinese puzzle, a n d those fellows have a tremendous amount o f work t o do, a n d t h e changing o f percentages adds t o the amount o f work.
flexible thing.

T h i s h a s been a very

F o r instance, Governor Young telegraphs

he i s i n a certain pcsition a n d requires a
Fisk 2 b a e

change.

W e

T h e n Governor T a l l e y will telegraph a n d

maybe Kansas City, a n d I think t h e committee feels t h a t
we are expected i n New York t o adjust particular cases,
and w e have always d o n e i t and advised everyhody, a n d
there has never been a n y objection.

W

e have g o t a

case r i g h t n o w f r o m G o v e r n o r B a i l e y w h e r e w e h a v e g o t

to make a special adjustment, take his Governments a n d
give him some bills t o fix u p his portfolio.
Governor Seay. Unless i t i s the general feeling
that t h e t a d j u s t m e n t s h o u l d b e m a d e o n a

quarterly basis,

I will withdraw any suggestion o f that kind. I merely
put t h a t f o r w a r d f o r c o n s i d e r a t i o n

o n the supposition


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that i t might b e somewhat t h e general experience.
The Chairman.
Wasi fiz. 1

I f y o u will write u s about this w e

ueg,

Governor Seay. P r i o r t o this year i t has b e e n o f
no c o n s e q u e n c e

t o u s whether

w e received a n y allotment

in the distribution o r not, because usually our bank
has o p e r a t e d w e l l w i t h i n t h e r e s o u r c e s

o f i t s o w n dis-~-

trict, b u t owing t o the conditions w h i c h prevailed last
year a n d t h e i n v e l v e d c o n d i t i o n s w h i c h w e h a v e b e e n

working o u t i n the borrowing class, o u r loans went
down t o a very l o w figure, making t h e carning assets
for t h e f i r s t q u a r t e r v e r y low, a n d w e w e r e g l a d t o

see them low.
The Chairman.

J u s t write u s a n d w e will take i t

up with the committee a n d f i x y o u up. T h e r e a r e times
when o u r p r o p o r t i o n

o f earning assets

i s larger,

and

while w e have o n l y a very small proportion o f the small
bills which cannot b e apportioned v e r y well, w e will
fix u p a n arrangement b y which y o u will g e t a special
alictment o f bills.
Governor Seay. This occasion m a y not arise again,
and v r o b a b l y w i l l not.


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Governor Talley.

Y o u d i d thet f o r u s last spring.

The Chairman. Yes.
Governor Talley.

W e took about s i x million Govern-

ments a n d replaced i t with small bills.
The Chairman.

Yes.

W

e have h a d every variety o f

transaction w i t h vou. G o v e r n o r G e e r y h a s b e e n i n
and out

with u s i n that way, too, haven't you, o n your portfolio?
Have y o u swapped Governments f o r bills?
Governor Geery.
The Chairman.

W e d i d once a couple o f years ago.

A r e there a n y other comments o n the

apportionment plan here and the figures submitted i n
connection with it?
Governor Talley. I

have nore except t o follow i n a

general w a y w i t h G o v e r n o r Seay.

experience last year, I
ber 2

toor not;

W

W

e h a d exactly t h e same

do not k n o w whether y o u remem-

e h a d t o crowd o u r allotment p r e t t y

heavily i n the last s i x menths o f last year, a n d a t one
time I

think w e had t o ask t o b e relieved o f about

$5,000,000.
The Chairman. Y o u would like t o start earlier?
Governor Talley.

W e would like t o start earlier a n d

spread i t out ever t h e year, i f w e could.


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The Chairman.
od o f apportionment,

I f there a r e n e comments o n the meth-~
w e will p a s s that, a n d there i s n o

eccasion t o take a n y action o n i t and n o motion before
the meeting, a n d t h e question i s whether w e have discussed under A

everything that should b e discusseq under B ,

Discount rates and policies."

D o you wish any further

discussien o n that subject? T h e r e being n o call f o r discussion,

w e w i l l c o n s i d e r t h a t covered.

I. Credit Transactions and Policies.
C. Relations w i t h Foreign Banks.
Report.

Status o f agreement w i t h Bank o f
Poland.

Status o f agreement w i t h National
Bank o f Belgium.
Purchase b y Federal reserve banks
of bills payable i n foreign currenCICS 5

The Chairman. U n d e r Topic co, "Relatitons with Foreign Banks," I

will a s k Mr. Harrison t o report o n that.

(The discussion o n this matter was, b y direction
of t h e Chairman,

n o t r e p o r t e d e x c e p t a s follows):

The Chairman.

T w o boards were good enough t o

write u s a b o u t p r o p o s a l s f o r p u r c h a s i n g b i l l s ,

and I

took

the liberty o f putting these t w o topics o n the program

because i t struck m e possibly that w e might have a n
illuminating discussion o n the matter.

O n e case was


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at Cleveland.

G o v e r n o r Fancher, h a v e y o u a n y discussion

of the question o f earsmarked bills?
Governor Fancher. U n e o f our member banks made inquiry o f u s a s t o w h a t w o u l d b e o u r a t t i t u d e

t f these

bills were offered, a n d I thought, before giving him a n
answer, I

would g e t a n expression f r o m your bank. H o w -

ever, there was nothing done.
The Chairman. T h a t ends i t ?
Governor Fancher. Yes.

The Chairman. T h e other was b y Governoy Wellborn
about buying documentary cotton bflls.
Governor Wellborn.

T h a t i s the letter f r o m the N e w

Orleans m a n that y o u refer t o ?
The Chairman. Yes.

Governor Wellborn. I
to discuss it.

de not know enough about that

H e has n o t sent i t t o me.

H e i s going

to sehd the man i n charge of the foreign exchange i n
to our bank t o discuss it, and I have never seen Mr.
Pool, t h e man whe wrote t h e letter,
him; t h e r e f o r e , I

do. I

t o discuss i t with

d o n o t k n o w e x a c t l y w h a t h e wants

to

a m inclined t o think that t h e proper procedure,

from what I

can r e m e b e r

o f it, w e c a n make h i m ad-


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vances

i f h e w a n t s them.

Y o u wrote m e that y e u d i d

not have a n y collecting facilities, a n d I think that
4t might b e satisfactory t o h i m i f w e just made a d vances t o him.
The Chairman.

T h e r e a r e t w o types e f transactions

either o f which h e may have h a d i n mind.

o n e i s the

type that Governor Talley knows a l l about, because h e
hes millions o f them.

H e buys a

dollar draft o n New

England o r New York o n a member bank, a n d attached t o
that i s the sterling draft, not yet presented for acceptance, representing i n his case a

foreign shipment

ef cotton, a n d a l l the papers respecting t h e cotton.
All that h e does i s t o make a n advance o n the collection
item i n dollars, a n d i t i s really collecting a documentary draft i n dollars a n d nothing more, a n d i t comes u p
to the N e w York o r New England b a n k o n which i t i s drawn
and that ends it.
The o t h e r c a s e m a y b e w h e r e s o m e b o d y d o w n i n y o u r

district wants y o u t o buy uneccepted drafts representing
the value o f cotton sold abroad, w h e r e t h e draft i s payable abroad i n foreign currency.

I f w e once start going

into that, w e have g o t t e open o u r doors t o going tnto


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the c o m m e r c i a l forceign e x c h a n g e business.
know h o w m u c h y o u w a n t m e t o e l a b o r a t e
remember

L d 0 ° not

o n that, b u t I

i n t h e B a n k e r s Trust. C o m p a n y i n
the ordinary

season w e bought a s much a s $200,000,000 o f those.

N o

bank runs a n open account i n any foreign currency f o r
any such volume a s that.
of the time.

H e i s selling against i t all

Y o u b u y your sterling drafts a n d sell your

demand sterling and the drafts g o forward b y the same
steamer which takes t h e bills against which y o u are
drawing, a n d i f w e once g e t t o competing w i t h o u r
member

banks doing commercial foreign business, w e would b e
in
hot water a l l the time. B e s i d e s that, w e have n o fae

cilities for handling those drafts abroad.

T h e banks

that w e correspond w i t h over there would never handle
these bills i n the world.

Governor Wellborn. Y o u mean the collection o f them?
The Chairman. Yes.

T h e y a r e owned bills a s soon a g

they a r e p r e s e n t e d a n d accepted,

a n d then w e have t o

carry t h e m o r discount them, a n d then w e are always i n

the market selling foreign exchange. Furthermore, a l l
of the valve i n those drafts expressed i n dollars i s
calculated against t h e rate o f discount i n London.


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Of course, a

Federal reserve bank might b e willing t o

do business o n a 3 per cent basis a n d carry those bills
to maturity, whereas e v e r y member b a n k has g o t t o figure o n the London discount rate, e r d w e have knocked
the stuffing o u t o f all o u r member banks.
not compete w i t h us.

T h e y could

S o i t would b e a very dangerous

type o f business f o r u s t o undertake o n that account.
The second thing i s that t h e handling o f these
cotton drafts involve j u s t a s complete a

knowledge o f

the credit o f a:cotton shipper a s a n y credit transaction y o u ever had. I

well remember cutting o f f ab-

solutely a n d d e c l i n i n g
paper a b o u t a

t o purchase a n y o f M i k e Yancey's

year b e f o r e t h e y busted,

a n d they had ten

or twelve million dollars o u t that went b a d completely.
Governor Wellborn.

C o u l d y o u gather f r o m his letter

what h e wanted t o do, what h e wanted t o ebviate o r
rather c h a n g e f r o m h i s p r e s e n t p r o c e d u r e ?

C o u l d you

gather from his letter what h e really desired?

fhe Chairmen. I

could not for the life of me tell

what h e was driving at.
Governor Talley. V e r y likely i t was t h e application
of t h e L o n d o n d i s c o u n t r a t e .


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Federal Reserve Bank of St. Louis

The Chairman. I

da not know.

Gevernor Wellborn.

H e did not write t o me.

H e wrate

to the Board a n d i t was referred t o m e and I wrote t o
you, a n d t h e n I
letter,

wrote

t o him a n d sent a

copy o f your

a n d h e said h e would have h i s foréign exchange m a n

at our next meeting, a n d w e will probably meet i n New
Orleans t h e next time a n d then w e c a n get into t h e real
merits o f the case.
The Chairman. I
mind.

will tell y o u what might b e i n his

H e i s a local dealer i n cotton bills.

when h e s e l l s t h o s e b i l l s

O f course,

t o your correspondent,

is a shave o n them naturally.

there

H e may think that the

Federal Reserve B a n k o f Atlanta h a s facilities abroad b y

which h e can get a little petter rate for his bills.
Governor Wellborn. T h a t i s the question I

want t o

ask you. S u p p o s e h e was t o ask m e couldn't w e open u p a n

account there with foreign banks, with the Midland i n
London o r with the National City branch i n Paris, o r
banks

o f that kind? I

want y o u t o u n d e r s t a n d I

a m not

crazy about getting into anything like that.
Governor Talley. I

will t e l l y o u w h a t i s e v i d e n t l y

the same sort o f a n inspiration, a n d h o w w e worked i t


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66
out i n principle, although I

do not know whether there

is a n y business being done along that line o r not.
worked i t out with o n e o f our large local banks.

W e

They

purchased t h e unaccepted sterling drafts w i t h t h e documents, a n d then they would issue their, own bill against
that, a n d then they sent t h e unaccepted sterling draft
acress t o their London correspondent a n d had i t accepted,
and then they sold demand sterling, a n d then they scld

their own bill i n the market.
The Chairman.

T h a t i s where t h e exchange transaction

is hedged,
Governor Talley.

T h a t simplifies t h e whole propo-

sition.
The Chairman.

T h e real question t o b e considered

connection w i t h h a n d l i n g c o t t o n d r a f t s
rencies

i s whether

in

i n foreign cur-

w e a r e going right o u t i n competition

with o u r o w n members.
Governor Talley.

T h a t method which I

tekes i t clear a w a y from us.

have d e s c r i b e d

W e d o not have anything

todo with it until that bf£1l bobs up in the market and
maybe comes b a c k t o us, a n d when i t comes b a c k t o u s
indorsed,

t h e n w e are a

p a r t y t o t h e transaction; o t h e r -


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Federal Reserve Bank of St. Louis

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wise w e are not.

H e gets t h e money from the market o n

his bill with which t o purchase h i s sterling.
question t h a t w a s a s k e d e f us, o f course,

The

w a s whether

that bill was eligible f o r acceptance.
The Chairman.

A s discount?

Governor Talley. N o ; a s t o whether i t was eligible
for acceptance.

S o I tock i t u p with the Board here

and there was n o specific ruling o n i t either way, b u t
in principle i t i s exactly t h e same a s a n acceptance i s
secured b y a trade acceptance payable i n foreign curremcy.
The Chairman.

W e have concluded Topic D

and n o w pass

to Topic E .
Credit Transactions a n d Policies.
E. Advisability o f standardizing r e -

quirements f
o Federal reserve banks
as t o forms e n d c h a r a c t e r

o f credit

statements.

The Chairman. That has been u p here before, but I
think Mr. Harrison can report what the previous action
was.
Mr. Harrison.
was s o m e c e n f u s i o n

A s a matter o f fact, I
i n the records

think there

i n the Board's letter

with regard t o the action o f the Governors! Conference,


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68
The o n l y reference that w e had t o the matter before a n d
the o n e w h i c h i s n o w o n t h e p r o g r a m r e l a t e s

t o the act-

ion which was discussed this morning a s t o the statements
with

f member banks.

S o that this specific question of

standardized forms a n d character o f credit statement
has n o t been before t h e Conference i n very recent years.
I do not know h o w long a g o i t might have been u p here.
Governor McDougal. I

think, Mr. Harrison, t h a t was

intended specifically t o treat w t t h the same subject t h a t
we have been treating i n the former subject I-D.
Mr. Harrison. T h e reading o f the Board's letter
X-4958 would s e e m t o justify t h e statement t h a t t h e y

are referring t o the same thing that w e were discussing
this morning.
Governor McDougal.

F o r t h e reason that t h e y refer

to the Advisory Council's treatment o f the subject, w h i c h
was confined entirely t o that f o r m o f statement.
Mr. Harrison® Yes.
The Chairman.

O u r position

i n New York i n the early

days w a s that w e should not attempt t o enforce a

uniform

statement u p o n borrowers i n our district t o the member

bank; that w e should not take the responsibility o f


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doing so. H o w e v e r ,

w e endeavored t o help t h e member

banks t o secure uniform statements f r o m their borrowers
by furnishing t h e m with typical forms which they could
use i f they were suitable t o the borrower, a n d w e have
as a matter o f fact g o t a set o f forms a n d where t h e
member banks want t o use those they are a t liberty t o d o
it. I f they want t o use some other forms f o r their customers, t h e y m a y d o so. I

think most o f the reserve

banks d o the same thing.

Governor Batley.
The Chairman.

W e have some.

T h e n t h e American Bankers! Association

is getting u p forms.
Governor F a n c h e r .

I n Cleveland t h e clearing h o u s e

association worked o u t a form which was i n use b y the

larger member banks, a n d also such forms were worked
out a s would f i t i n the case o f the small borrowers, a n d

when a bank would write i n inquiring about forms, w e have
usually referred those communications

t o the clearing

house and have supplied themselves with those forms i f
they w a n t e d t o adopt i t , a n d i n t h a t w a y t h o s e f o r m s a r e

now used throughout o u r district.
The Chairman.

O f course w e could n o t pretend t o


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furnish a

pro forma statement t o a concern w i t h a lot

of subsidiaries.

I t would b e out o f the question.

Governor Seay- The forms which have been adopted
in the Cleveland district v a r y from those adopted i n the
Richmond district.

T h e r e have b e e n t w o efforts m a d e t o

arrive a t some fairly uniform standard. T h e Federal Reserve Board made some effort here, a n d they asked t h e
credit m e n o f s o m e o f t h e b a n k s

t o come u p here a n d a i d

them, a n d they were here f o r several weeks.

B u t I

think

the general opinion i s that i t i s a n impracticable thing.
The Chairman.

W o u l d y o u b e satisfied a t this

meeting t o pass a resolution that i t is the sense o f the
meeting that i t should b e the policy o f the reserve
banks t o aid the member banks i n obtaining suitable forms
of credit statements f r o m their customers,

i f necessary

by furnishing forms, b u t that w e should n o t attempt t o

force uniformity i n credit statements, a n d our attitude
shoulda b e t o render assistant i n getting uniform statements, b u t i t should n o t b e our policy t o require it,
and 1 t w i l l b e i m p r a c t i c a l

t o d o it.

Governor S e a y . T h a t w o u l d b e m y v i e w o f it.

Governor Bajley. I

would like t o second that motion.


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Federal Reserve Bank of St. Louis

Governor Fancher. I

-sécond It.

(The motion was put and unanimously carried.)
The Chairman. A

memorandum I

have before m e o n this

same subject refers t o a suggestion which was raised I
think with the Federal Reserve Board counsel a s t o
whether t h e Pederal Reserve System should attempt t o require audited statements.

N o w , o f course t h e credit

system o f this country i s developed wholly different f r o m
that which prevails abroad.

M o r e companies a n d corpo-

rations especially a r e having public auditors audit
their books a n d certify t o them, b u t i t seems t e m e that
to require that would b e just a
thing.

perfectly impossible

T n e amount o f auditing required would probably

tax t h e audititing facilities o f the country beyond what
they are capable o f meeting.
Governor Fancher.

D o e s net that really get back

to the policy o f the bank i n extending credit affecting
paper?

I

f i t feels

i t should h a v e a n audited state-

ment i t should b e initiated b y the bank. O f course,
the f a c t s a r e t h a t m o r e a u d i t e d s t a t e m e n t s a r e b e i n g

required.
Governor Talley. W o u l d n ' t y o u s a y that more audited


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Federal Reserve Bank of St. Louis

statements a r e being made?
Governor Fancher. Yes, made, a n d I think required.
I think t h e b a n k s

i n some states

Governor Seay.

d o r e q u i r e them.

T h e practice i s undoubtedly grow-

ing, b u t i f you make i t a requirement t h e banks would
rebel.
Governor Norris.

T h e recommendation

c f the Advisory

Council was against it.
Governor Seay. I

do not recall.

Governor Norris. Yes, unqualifiedly against it,
that i t i s impractical.
The Chairman.

D o e s someone want t o offer a motion?

Governor Wellbern. I

think w e a l l a g r e e t h a t t h a t

is the best thing t o do. T h e r e i s n o doubt about it,
audited statements w e find have been very unreliable,
and when a bank fails a n d the real assets o f the debtor
are inquired into, t h e y d o not exist.
Governor Seay. W e l l , w h a t y o u refer t o i s a collateral question, M r . Chairman, w h i c h i s not embraced--

The Chairman (interposing) . I t i s not o n the program.
Governor Seay. T h e n I would n o t think that a n y
vote was needed o n thse subject.


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73
Governor Talley.

I t was i n the program o f the

Advisory Council..

The Chairman. Yes, a n d that i s the w a y i t came up.
We c a n pass i t without a n y action, becavse fit i s not
on our program,
I. C r e d i t Transactions a n d Pelictes,.
F. Classification o f deposits i n member
banks b y building a n d loan assoctations,
mutual savings banks, ccoperative banks,
credit unions a n d Morris P l a n banks.
Governor Norris. I

would suggest that w e hear f r o m

the bank that sent that inquiry t o the Board, a s t o the
purpose o f it.
The Chairman.

W h i c h bank made inquiry c f the Board

which gave rise t o the Board's suggesting this topic o n
the program?

Governor N o r r i s .
has r e c e i v e d

T h e Board's letter s a y "The Board

f r o m one o f the Federal

reserve banks

a n

inquiry as to whether deposits o f such and such a kind
d be carried
l
as demand
u
or
o time deposits,’
h
s " and s o
forth.

Governor Geery. That is, demand o r time?

Governor Norris. Yes, and I said "and se forth,"
Governor McDougal. “ A g a i n s t which t h e amount d u e


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74
from banks cannot b e applied i n arriving a t their re-

gerve requirements."
Governor Harding. B o s t o n pleads n e t guilty.
Governer Norris. Apparently n e bank made t h e inquiry.

Governor Geery. I

cannot see, f r o m m y point o f

view, w h a t difference i t makes. I

d o not know o f a n y

bank which takes country bank business t h a t has n o t g o t
a great deal more country b a n k balances t h a n t h e farm
bank amounts to.
Governor N o r r i s .

C e u n t r y banks, y e s .

Governor Geery. S u p p o s e y o u a d d t o this, y o u d o

not change t h e reserve ratio a t all, because y c u c a n
only deduct t h e ameunt y o u have d u e from banks, a n d t h e
rest o f i t would b e demand deposits.
the reserve proportions a t all.

I t dees n o t change

T h e o n l y place T — can

see where i t would have a n y effect would b e i n a case
in New England.

Y o u might have a national b a n k i n

Springfield that had an account with a mtual savings
bank i n Springfield that h a d n e other b a n k accounts

at all, and they would b e allowed t o deduct "due from
banks.”


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Governor Harding.

W e d i d not raise this inquiry.

Governor Seay. M r . C h a i r m a n ,

t h e Board has ruled

that building a n d loan associations a n d mutual savings
banks a n d private banks d o net come within t h e meaning

of the word "bank" as used i n the Federal Reserve Act.
That being t h e ease, I

do not. see h o w balances d u e t o

those banks could b e deducted.
Governor Norris. Counsel f o r t h e Board has given a n

opinion that mutual savings banks are banks within the
meaning o f the Federal Reserve Act.
The Chairman, T h e Board has made t h e ruling that

Governor Seay mentions, a n d consequently cannot make the
deductions suggested b y this inquiry, whoever m a d e then,

and i t involves a change i n the rulings o f the Board,
The question now is whether i t would b e wise for this
Conference t o recommend a n y such change a s this. This
matter was considered a t ene bank, a n d one o f our men
expressed his views, w h i c h I think a r e scund, a n d I
wonder i f Mr. Harrison will n o t read this.
Mr. Harrison (reading):

"On the basis of existing rulings, therefore,
it seems clear that deposits o f the character under


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76
discussion cannot b e considered a s balances ' d u e
to banks.'!

"It i s presumed that the Board wishes t o have
the matter considered, however, o n its merits and
quite regardless o f previous rulings.

"It i s understood that the paragraph quoted
above f r o m t h e A c t i s the result o f a n attempt t o
make legal a

practice which h a d existed w i t h the

appreval o f the Comptroller o f the Currency prior
to t h e e s t a b l i s h m e n t

o f the Federal Reserve S y s t e m

under which banks h a d been permitted t o offset balances ' d u e t o banks! w i t h balences ‘ d u e f r o m
banks!

i n computing reserve requirements.

This

practice p r o b a b l y w a s b a s e d e n t h e t h e o r y t h a t b a l -

ances d u e from banks represented i n censiderable part
items

i n process

o f collection,

t h a t i s uncollected

funds, a n d also t o the extent that i t did not represent uncollected items, t h a t t h e funds w e r e available
for t h e liquidation o f deposits.

I t may have been

argued that s u c h balances ' d u e f r o m banks,' while
entitled t o consideration i n the matter o f reserve
requirements, o u g h t n o t t o b e permitted a s a deduct-


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Federal Reserve Bank of St. Louis

i 4
ion from gross deposits, b u t o n l y from balances
due t o banks o n the theory that i n times o f stress
there would t o a considerable extent b e a n offsetting o f bank balances.

"In the light of present-day banking methods
the whele procedure i s unsound a n d antiquated.

There

ids no basis i n fact warranting the deduction o f
balances ' d u e from banks! f r o m anything. D e d u c t iens, i f made a t all, should represent o n l y items i n
process

o f collection

should b e r e q u i r e d

o n t h e t h e o r y t h a t n o reserve

o n deposits u n t i l t h e d e p o s i t

represents c o l l e c t e d funds,

a n d s u c h deductions,

if

permitted, s h o u l d b e from gross deposits rather
than balances t d u e t o banks.!

I t i s recognized,

however, that such a procedure would require a change
in the Act which cannet b e a t once accomplished.

Therefore, dealing with the question i n the light
of the Act a s i t n o w stands, -

"It is recommended that f t would b e inadvisable
to make a n y more liberal interpretation o f the intention o f the Act than i s necessary a n d inasmuch
as t h e p r e s e n t r u l i n g o f t h e B o a r d d o e s n o t permit


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7S

the classificationf
o deposits cf the character
under discussion a s balances d u e t a banks,

it eed

be better t o let matters stand a s h a t bing e s
than t o further liberalize it.
"As t o whether s u c h deposits s h o u l d b e classi-

fied a s demand o r time depesits, that obviously
would have t o depend upon the ccenditiens under which

the depesit i s taken.

I f the bank holding such de-

posits h a s t h e legal right t o require thirty days!
notice o f withdrawal o r i f i n other respects t h e
depesits m e e t t h e test o f time deposits, t h e n they

should be so considered, otherwise they sheuld be
considered demand aceeeken*
Governor McDougal.

T h a t is a

very s e n s i b l e s t a t e -

ment w i t h r e g a r d t o t h e w h e l e matter. I

d o not bélieve

the Beard's rulings, though, covered Morris P l a n banks.
Governor Norris. M o r r i s P l a n banks a r e n t banks a t

all.
Governor McDougal,

I n considering t h e application

of the provisions o f the Clayton Act, I

understand thet

Morris Plan banks are considered a s banks.
Governor N o r r i s . I
t is hard t o know when a ‘bank i s


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Federal Reserve Bank of St. Louis

or i s n o t «

bank now,

Governor Wellborn.
Governor Fancher.

T h e y a r e not banks o f deposit.
O u r c o u n s e l says:

"The Supreme Court o f the Upited States had
held that banks i n a commercial sense a r e o f three
kinds: ( a ) e f deposit; ( b ) o f discount; ( c ) o f circulation. T h e y further h e l d that a

bank which exer-

cises b u t o n e o f these functions i s a bank i n the

strictest commercial sense. W h i l e this court decision i s obviously a n old one i t 1 s quoted b y the

Attorney General i n opinion published i n the Federal
Reserve Bulletin No. 27, page 268. S i n c e all o f
these organizations exercise one o r more o f the three
above-mentioned functions, f t clearly follows that
Ina technical sense they are banks, a n d f f a n institution where such balances a r e carried choases t a
qualify t h e m a s fdaue t o t , I can see n e w a y i n which
it c a n b e avoided.

"TJ have discussed this matter with Mr. Newell"-Mr. Newell i s our attorney.
"..-who has confirmed this cpinion.”


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80
Governor Seay.

T h a t i s not t h e opinion o f our

counsel, M r . Chairman, a n d h e gives a n opinion v e r y
analagous t o that r e a d b y Mr. Harrison.

S u m m e d up in

one sentence, it-is t e the effect that mutual savings
banks, c o o p e r a t i v e b a n k s , c r e d i t u n i o n s a n d
Morris
Plan-banks

d o n e t u n d e r t a k e ‘the c o l l e c t i o n o f
checks

on a-large scale, a n d i t seems a

deposit balance d u e ‘by

& commercial b a n k t o such a n institution cannot
‘be dits-~
‘tinguished f r o m a deposit balance d u e t o a n y other
eustomer.
The Chairman. N o n e o f them urdértake t h e collection
of checks a s collecting agencies.
Governor Fancher. A n d they d o not a s a rule carry
checking accounts.
The Chairman.

M u t u a l savings b a n k s i n o u r district

are n o t r e a l l y permitted.

Governor Talley.
loan association,

W i t h reference t o the building a n d

t h e y c a r r y n o reserve themselves a n d

are not required i n our state.
are specified.

T h e form o f investments

I n view o f the fact that t h e y carry n o

reserves a n d their balances w i t h other banks a r e
merely
investments w i t h t h e banks, t h e banks should carry
full


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Federal Reserve Bank of St. Louis

reserves a g a i n s t t h o s e balances.
The Chairman.

W e are n o t lawyers a n d don't y o u

think w e are justified i n passing a resolution-that.
the Board make n o change in: the existing regulation?
Governor Talley. I
Governor Geery. I

make that motion.
second it.

(The motion was put and unanimously carried.)
I. C r e d i t Transactions a n d Policiés.
G. D e v e l o p m e n t

o f investment companies

for purchase o f bank stocks.
The Chairman.

This m a t t e r - h a sd
a
h a

v e r y a c t i v e de-,

velopment i n our district.

Governor Talley.

D o yey include investment trusts

in that?
The Chairman.

Yee

W

Their business i s analyzed.
the investors i n quite a

e have a

l i s t eof all o f them.

W e even have a list o f

n u m b e r fo them.

Governor Seay. H o w many o f them are there, Mr.
Chairman, without counting--a hundred?

The Chairman. There are sixteen.
Governor Harding. That 1 s just the New York district?

The Chairman. J y s t N e w York. I

d o not know what t o


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Federal Reserve Bank of St. Louis

B82
do a b o u t t h i s report,

i t i s s o long. P r o b a b l y t h e

best thing t o do, Mr. Harrison, w i l l b e t o ask for a n
exchange

o f views

o n this subject. I

think y o u h a v e

got t e watch it.
Governor Fancher. I
interesting

think t h a t r e p o r t w o u l d b e v e r y

t o all o f t h e Governors here.

Couldn't

we

have c o p i e s m a d e ?

The Chairman.

I t i s thirteen pages.

Governor McDougal.

D e these sixteen companies y o u

refer t o mean companies specializing i n bank stocks?
The Chairman. N o t altogether i n bank stocks, no.
I can give y o u a lot o f them.
(The Chairman here read t h e list c f companies f r o m

the report.)
The Chairman (continuing). T h i s winds u p with a
recommendation which I will have Mr. Harrison read t a
you, a n d then, i f you would like a report c n this, w e
will b e glad t o have that struck off a n d send i t around.
Mr. Harrison.

A f t e r reciting these various com-

panies t o which Mr. Strong has’ just referred, t h e memorandum c o n c l u d e s

w i t h this recommendation:

"That a t ur early date there b e held confer-


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83
ences o f the cfficers o f the Federal reserve
banks w i t h the Comptroller o f the Currency, t h e
Chief National B a n k Examiners a n d t h e Su:erintendents

o f Banks f e r t h e p u r p o s e

o f considering

this general problem and working out plans for dealing with i t t n each Federal Reserve District.
Among t h e m e a s u r e s w h i c h s e e m d e s i r a b l e a r e t h e

following:
"1, Examinations o r investigations o f companies engaged i n purchase c f bank stocks should b e
made b y the appropriate State authorities a n d efforts
should b e m a d e t o h a v e s u c h c o m p a n i e s p u b l i s h f r o m

time t o time statements o f their financial condition
and l i s t s o f t h e s e c u r i t i e s h e l d b y them.

"9, Frequent and searching examinations o f
banks included i n chains centrolleg b y these com-

panies should b e made.
"3, T h a t i n the examinations c f all panks,
loans t o companies o f this k i n d o r loans based
upen their stock should b e set out i n the examination
report.

"4, T h a t i n case where circumstances warrant,


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84
the attention o f Atborney General o f the state
be called t o the operations o f any particular
company which i s engaging i n illegal practices."
Governor Seay.

T h a t i s treating t h e matter quite

seriously.

Mr. Harrison.

W e think i t i s serious.

Governor Seay. G o v e r n o r McDougal, there w a s some
report

i n a t least o n e o f t h e papers

eity, I

o f parties

i n your

think, w h o signified their purpose t o organize

a national b a n k i n every Federal reserve a n d branch city
in t h e country.

Governor McDougal.

I f that i s this fellow Parker,

I think his name is, h e has n e standing and h e is not
looked upon with a n y fear o r apprehension a t all.
Governor Fancher. H a s n ' t h e transferred h i s activities f r o m Chicago t o New York?

Governor McDougal. That I do not know.
Governor S e a y .

H e i s r e p o r t e d toa have t a k e n t h e

view that t h e National B a n k Act required t h e Comptroller
to authorize t h e organization o f a national b a n k when
the required number o f persons applied tno him for that
purpose, a n d that h e had n o discretion; but, a s w e


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85
know, t h e Comptroller j s beginning t o exercise a

very

mich c l o s e r s u r v e i l l a n c e o v e r t h e o r g a n i z a t i o n o f n e w

national banks.

Governor McDougal.

T h a t i s the attitude that h e

displays w i t h r e g a r d t o this. -

discussed a

I have h e a r d t h e m a t t e r

good deal o u t there, because o f the news-

paper publicity t h e y have given it, b u t i t seems t o m e

more talk than anything else.
Governor Fancher. I

do know that t h e Better Busi-

ness Bureau i n New York camped o n brother Parker's
trail,

a n d t h e y h a v e g o t h i s number.

H e will have a

hard time t o get very far.
Governor Norris. I

think this i s a n interesting

and important development i n American finance.
question t h a t a r i s e s

i n m y mind, h o w e v e r ,

T h e

i s whether a n y

steps that ought t o be taken i n reference t o it should
be initiated b y us o r b y state o r national banking au-

thorities o r blue-sky commissions, o r whatever they are
called,

o r b y some organization o f bankers. I

it i s a g r e e d t h a t t h i s i s n o t p a r t i c u l a r l y a
reserve p r o v i n c e ,
ment t h a t ,

suppose
Federal

a n d i s i t s u c h a n important develop-

i n the absence

o f a c t i o n b y a n y b o d y else,


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Federal Reserve Bank of St. Louis

86
there i s a moral obligation o n us t o start sone action?
Governor Talley. I

would s a y that, inasmuch a s i t

affects t h e stockholders't liability i n certain banks,
yt i s a Federal reserve matter.
Governor Norris. I

do net think i t does.

I f any

one o f t h e s e c o m p a n i e s w a s o r g a n i z e d f o r t h e p u r p o s e

of acquiring the stock o f one bank o r one chain o f banks,
then would affect t h e stockholders! liability a n d all
their eggs would b e i n one basket, a n d i n case t h e bani
er chain o f banks went wrong there would b e n e other
assets there that y e u could collecs from.

B u t most

if not a l l o f them scatter their investments a n d hold
stocks

i n various d i f f e r e n t b a n k s ,

a n d most o f them

not o n l y i n banks b u t i n insurance companies a n d other
concerns.

S o that thet being t h e case, I

d o not s e e

that t h e stockholders! liability i s affected,
Governor Talley.

Of course, w
e are pretty f a r

from the scene o f action o f such enterprises, b u t w e
feel a great deal c f concern about i t a s affecting t h e
general banking situation, a n d I have prepared a short
memorandum h e r e w h i c h I

would l i k e t o read:

"Assuming that Topic G, - Development o f


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87
investment companies f o r purchase o f bank stocks--=
ts closely related t o the topic which i s generally
current a n d r e f e r r e d

t o a s investment trusts, t h e r e

are three points w h i c h might b e briefly made.

"First | if investment companies which are ormenized f o r t h e purchase o f bank stocks a r e operated
along t h e lines o f the socalled investment trust,
as such organizations h a v e been recently established,
then t h e p r a c t i c e

w o u l d b
e a

matter

o f some c o n e

cern a n d some sound regulation that would n o t b e
irksome t o a sound enterprise, b u t would prevent
unsound practices, s h o u l d b e established.

"Second, i f the question is. clearly established that stockholders! liability would b e
eliminated t h e object o f that provision o f l a w

would b e defeated; then certainly investment companies organized f o r t h e purpese o f owning bank stocks
are unsound i n principle,

i f not. tilegali.

"Third, t h e organization o f helding companies
for the purpose o f owning the stcecks c f small individual institutions a n d a t the same time owning

the control o f e« larger institution i n order that


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Federal Reserve Bank of St. Louis

88
such small individual institutions might b e operated for a l l practical purposes a s branches o f
the large institution, w o u l d defeat t h e objectives
and purpeses o f the Act o f February 25, 1927, k n o w n
as the McFadden Act, a n d would b e i n effect detrimentally competitive t o those larger individual i n stitutions w h i c h a r e located i n states which d o
not permit branch banking.

"The point which i s made i n the second subdivision above would b e ene e f consideration i n
connection w i t h this principle. M o r e o v e r , t h e
opportunity f o r indulging i n the unsound practices
that frequently appear i n what i s known a s chain
banking would n o t necessarily b e eliminated b y
reason o f t h i s practice.

What I

see i n t h e t e n d -

ency o f the socalled investment trust i s that t h e y
are fair weather enterprises a n d a s long a s stocks

are moving upward, everything i s lovely."
Governor Biggs.

M r . Chairman, I

would like t o

raise t h e p e i n t h e r e a s t o whether t h i s c o n d i t i o n p r e vails

i n a n y c t h e r district.

T h e s e investment companies

have been buying o u r best b a n k stock f o r sixty days.


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They have raised t h e price o f four different b a n k stacks
from$35

t o $60 a

share.

O n e concern very frankly

stated that t h e y have s o many shares o f the First
National Bank, a n d t h e y c o u l d n o t g e t t h e m a n y w h e r e n e a r
the m a r k e t a n d t h e y w e r t o u t a n d p a i d a n a d v a n c e

of

$50 a share for a s much as was advertised for sale.

Since then the stock has gone u p $30 or $40 a share o n
that situation, a n d all four a r e four o f the largest
banks there, a n d o n inquiry I
these investment companies.

find that i t i s due t o

T h e r e i s nothing that

would justify that stock going a n y higher, because t h e y
are n e t m a k i n g a s m u c h m o n e y o r n o m o r e m o n e y t h a n t h e y

were making a

year ago, a n d i t i s getting beyond a divi-

dend-paying basis, and I was just wondering if thet
same thing was hciecon die i n ether districts.
Governor McDeugal.

I s this a

St.Louis enterprise

that i s doing t h e buying?

Governor Biggs. N o .
Company.

I t is called the New England

T h e y have salesmen going around a n d soliciting

peonle t o take what they call a participation, stating
they have got s e many industrials a n d then s o much o f
the good bank stock, a n d they say, "Here i s what you


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are participating in; y e u know all o f these institutions a n d y o u c a n l o o k t h e m u p a n d m a k e i n q u i r y , ”

and

they a r e selling real stock there e n that business t o
& l o t o f people.

The Chairman.

Y o u speak o f that development i n

St.Louis i n terms that indicate that y e u feel some concorn.
Governor Biggs. I
The Chairman.

certainly do.

I f v o u came t o N e w York a n d learned

the h i s t o r y o f s o m e o f t h o s e t h a t w e r e d e v e l o p e d

York, y o u would g o t o a hospital w i t h concern.

i n New

What I

mean t o s a y i s t h a t o n e i n v e s t m e n t c o m p a n y b o u g h t i n -

vestments i n bank stocks,has securities cutstanding
today i n N e w Y o r k t h a t h a v e a

market v a l u e o f o v e r

9125 ,000,000.
Governor Biggs.

I n that connection,

i n making

this inquiry a n d talking t o the officers o f the bank,
I found that this fellow o u t i n California h a d been
buying b a n k stock i n five o f the biggest banks o f

St.Louis for a year, just a s fast a s he could get it.
The Chairman.

T h e r e seems

are elements o f danger i n it.

t o b e n o doubt t h a t there

O n e o f them t s the one


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Gevernor

Talley referred to, that these stocks have

double liability.

n o

M o s t o f them are incorporated

in cur state under statutes o r the statutes o f other
states w i t h o u t a n y d o u b l e l i a b i l i t y provision,

and

consequently t h e creditors o f the bank whose stock i s
held b y this i n v e s t m e n t c o r p o r a t i o n

d o not get t h e

benefit o f the double liability i n the same complete
sense that t h e y d o i n other cases+

T o b e sure, where

the company i s large and they hold a variety o f securities, t h e y would g e t protection, b u t where t h e y confine their purchases t o one o r two banks t h a t might
go d o w n i n a crash, t h e p r o t e c t i o n
is lost.

c f double liability

T h a t i s e n e denger undoubtedly, p o s s i b l y a

less o n e that some o f the others.
The second danger i s that there i s speculation i n
this s t u f f ,

i n the investment

ment companies.

o f s t o c k o f t h e invest-~

A s they g o u p i n velue t h e y c a n mar-

ket more stocks a n d b u y more b a n k stocks a t higher
prices,

a n d p e o p l e a r e l e d t o b o r r o w i n o r d e r t o specu-

late i n these investment company stocks, a n d something

might come along and prick the bubble and then the
sharp decline i n the stock o f the investment companies


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is very liable t o affect t h e credit o f some bank with
which i t i s associated.
Gevernor Seay.

I f i t controlled t h e hceldings

of that bank stock i n the market.
The Chairman. Yes.

B u t I mean mest o f these con-

cerns i n New York have b e e n crganized b y individuals
who a r e associated with some particular bank. I

went

mention a n y names, b u t y o u prebably k n o w seme o f them.
Almost e v e r y o n e h a s b e e n o r g a n i z e d a s a n a t t a c h m e n t

to

@ commercial b a n k o r e« trust company, a n d the development o f the speculation o f this stock a n d the possible
collapse

i n its value might b e construed

b y t h e public

to indicate t h a t there i s something wrong w i t h the
bank, a n d they might start a run o n the bank itself.
Wwe have t a k e n i t u p w i t h s e m e o f t h e s e f e l l o w s
and a t l e a s t m a d e i t p e r f e c t l y c l e a r t o t h e m t h a t w e
did n o t l i k e t h e w a y t h i n g s w e r e going.

T h e question

arises a s t o whether i t i s a n y o f our business a t all.
I have a feeling that where a

concern o f this sort i s

organized i n close affiliation with a member bank and
that m e m b e r b a n k m a k e s l o a n o n t h e s t o c k o f t h a t concern,

and they have a sort o f interlocking arrangement f o r


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transactions o f one kind a n d another i n securities,
that i t m a y b e v e r y m u c h o u r business,

b u t w e have n o t

any f o r m u l a d e v i s e d f o r d e a l i n g w i t h i t , b u t I

ginning t o have a

a m be-

feeling that i f this thing i s going

on m u c h f u r t h e r w i t h t h e s t a t e b a n k s a t least, w h e r e
we h a v e s o m e c o n t r o l

o f t h e membership,

w e m a y b e obliged

te say to them, “If you want t o continue members o f the
Federal Reserve System,

w e are going t o have t h e right

to examine that investment company.”

I t is rather

puzzling, because the superintendent o f banks has n o right
to examine them, apparently.
Governor Fancher.

T h e y are organized under t h e

general incorporation laws?
The Chairman. Yes, sir.

Mr. Fancher. With no stockholders! liability?
The Chairman.

N o . S o m e o f them a r e incorporated

under t h e laws o f other states.
Governor Seay.

If a

bank should m a k e l o a n s

o n the

stock o f a n investment company which held stock i n the
bank, i t would b e equivalent t o lending o n its o w n
stock?

The Chairman. T h e r e w a s a

concern organized i n New


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Jersey that bought t h e majority o f the stack o f a
bank, about 8 0 o r 9 0 per cent, I

think, t h e investe-

ment company did. T h e very first crack o u t o f the b o x
they went t o the president o f that bank a n d t h e y seid
he had t o take t e n thousend shares o f that stock.

He

said, " I wont d o it." T h e y said, " I guess w e know
whe owns this bank, " and h e went t e the court a n d said

"How about that?"
not.

H e said, "They went." A n d they did

T h a t i s net t h e present situation.

There was a big insurance company and a trust company i n New Jersey where o n e bought t h e stock o f the
other, a n d vice versa, a n d t h e courts t o r e that apart
and m a d e t h e m separate.
I d o n o t l i k e t h i s development. I

do not like

speculation i n bank stock. T h e fact i s that b a n k stocks

in New York have gone u p 50 per cent i n value, but a
part o f the advance h a s undoubtedly b e e n d u e t e the
unlicensed purchase o f stock b y these investment companies,

a n d when y o u l o o k over t h e lists

o f the se-

curities which w e have o f some o f them, they have
millions a r d millions o f dollars o f bank stock a t
constantly rising prices.


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Governor Talley. Y o u mean t h e y have gone u p i n
price a n d n o t i n value?

The Chairman: Yes, sir.

Governor Talley. I
the c p e r a t i o n s

would like t o ask Wr. Day about

o f t h i s m a n o u t i n California.

Geverneor Day. T h e Bank of Italy Corporation was organized i n June, 1919, w i t h a million dollars o f capital, a n d they have gone f r o m 1919 t o Uctober, 1927, t o

a fully paid up capital o f $130,000,000, with total surplas o f $235,000,000.

T h e last statement w e have i s

Lctober SOth, 1926, w h e n they designated t h e y h a d

$40,917,000 worth o f domesti¢ bank stock i n their invest-

ment trust and $10,751,000 worth of foreign bank stock.
They o w n stocks i n every important b a n k .

in every

important c i t y i n the world.
Governor McDougal.

W h e r e does this enormous capital

and accumulated surplus c o m e from?
Gevernor D a y . M e s t l y f r o m t h e public, I

should say.

Governor lMeDougal: D e e s i t come a t all from washing
out t h e book value?

Governor Day. I imagine i t does, but I have n o information a s t e that.

B u t t h e y a r e continuously giving


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the public opportunity t o participate a t prices slightly below t h e market a n d later o n declaring stock dividends.
The Chairman. A n d then they issue t w o classes o f
stock, o r more, a n d give t h e dear public a

limited par-

ticipation i n the appreciation a n d keep t h e unlimited
participation themselves?
Governor Bank. N e t i n the Bank o f Italy, no.
Governor McDougal.

I t would b e interesting t e see

to what extent somes o f the organizations a r e operating
in other cities.

W e d o not k n o w o f a n y corporation

of that sort i n Chicage o r i n our district.
The Chairman.

W e l l , y e u know that this California

ene m a y o p e r a t e there.
Gevernor l i c D e u g a l .

W

e m a y assume,

f r o m what

w e

have b e e n told b y New York, t h a t t h e operations o f these
sixteen c o m p a n i e s h a v e a

gocd c e a l t o d e w i t h what h a s

happened t o our bank stocks too.
Governor Fancher. I

think i t i s very significant

about t h e attitude o f the public w h e n y o u see t h e Bank
of Italy Gorporation trading o n the N e w York curb t o
the extent o f 37,000 shares i n one d a y a n d selling


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Federal Reserve Bank of St. Louis

115, 1 1 6 o r 117. S o m e b o d y owns t h e stock.

The Chairman. Why, Governor Fancher, these banks
uptown--there

is a

small people.

S o m e o f t h e smaller uptown banks

lat o f speculation u p t o w n among t h e
in

New Y o r k C i t y i n f o r m e d M r . C a s e t h a t t h e r e a s o n w h y

they come t c u s f o r credit more t h a n they usually a r e
exnected i s that their customers h a v e drawn their money
out i n order t o b u y t h e s e i n v e s t m e n t c o m p a n y s t o c k s a n d

bank stocks, a n d their balances therefore a r e reduced
to a

point w h e r e t h e y h a v e t e b o r r o w m o r e t h a n usual.

We asked them all i f they a r e lending very largely,
and s o m e o f t h e m a r e i e n d i n g t e o h u c h s

W

e d o not

run every o n e o f the banks i n our district;
do m o r e t h a n r e m o n s t r a t e

u p to a

w e cannot

certain point,

but

we are making i t a little uncomfortable t o some o f them.

Governor Biggs.

H o w do you make i t discouraging

for t h e m ? W h a t d o y o u d o ?

The Chairman. W e l l , w e intimate t o them that w e
de not like very much, a n d w e are watching how much
they borrow f r o m u s when t h e seasonal demand comes along.
That i s a pretty strong intimation t o the uptown banks,
because t h e y a r e absolutely dependent except during t h e


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season when they are manufacturing i n the spring. N o w
they p a y off, b u t i t i s i n the spring that t h e y borrow
$t%

Governor Seay. They cannot object t o the withdrawal
of the money o f their depositors.
The Chairman. N a , b u t i f w e find they are lending
we have a

little t a l k with them.

M y recommendation t e

the m e e t i n g f o r a c t i o n i s t h a t w e h a v e a

little i n q u i r y

made i n each locality a n d get o u r reports a n d exchange
them between e a c h banks; l e t each bank make u p a dozen
reports a n d send t h e m t o each o f the others.
Governor Norris. Wouldn't i t b e better t o get u p
a questionaire t h a t w e c o u l d a n s w e r , b e c a u s e

w e d o not

know what points y o u have covered i n your report?
The Chairman. What. d o you say, Governor McDougal?
Governor McDeugal. I

suggest that perhaps those

who a r e here a r e i n a position t o report n o w a s t o
whether t h e s e c o m p a n i e s a r e o p e r a t i n g

The Chairman. I

i n t h e i r districts.

would like t e see a written report

that w e could assemble. P o s s i b l y t h e best w a y t o get a t
that would b e for u s t o make o u r report a n d send i t
around a n d that would b e a guide.

N e w York i s where


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Federal Reserve Bank of St. Louis

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most o f this h a s developed lately i n nuibers, a n d w e
could h a v e t h i s r e p o r t e l a b c r a t e d q u i t e a
ulars.

T h i s report

i s rather a

b i t i n partic-

casual, o f f - h a n d s t a t e -

ment, b u t w e will p u t some o f our fellows o n the j o b
very t h o r o u g h l y a n d g e t a

real r e p o r t a n d s e n d i t around,

and i f you gentlemen c a n d e the same thing that will
be very helpful.
Governor Talley.
any district.

I t i s a thing that c a n invade

I t may have invaded curs, I

do not know

yet, a n d i t would take a n inquiry t o develop that.

Governor Seay.

I f i t can g o into 5t.Louis i t can

go into o u r district a n d d o the same thing, a n d then
you would not have t o make a n inquiry t e find c u t about
it.
Governor Wellbarn. I

da not think t h e y would have

the temerity t o come i n t o t h e Sixth District since t h e
failure

o f t h e Atlanta banksand others

i n Georgia a n d

Florida.
The Chairman.

I f you will permit me, w e will have

the ceport started a t N e w York a n d send i t around, a n d
if w e follow that general l i n e maybe t h a t will b e enough.

There i s quite a little inquiry about this i n New York.


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The Attorney General o f the state i s making a n investigation.
Governor S e a y .

T h e r e i s alse a n inquiry into

these i n v e s t m e n t t r u s t s .

H a v e n ' t questionnaires

o f dif-

ferent c h a r a c t e r b e e n s e n t o u t b y y o u r s t a t e b a n k i n g d e partment?

The Chairman. Yes.
ment trusts,

T h a t w a s described a s invest-

b u t i t includes a l l o f these.

Stands a g t h e action o f the meeting,

I

f that

w e will pass t o the

next topic, H , preposed b y Dallas.
I. C r e d i t Transactions a n d Policies.
H.What effect will ruling o f Supreme Court
of Texas t h a t t r a d e a c c e p t a n c e s a r e n o n -

negotiable which bear the legend - "The
obligation o f the acceptor hereof arises
out o f the purchase o f goods f r o m the
drawer, maturity being i n conformity with

the original terms of purchase"--have
upon t h e negotiability o f bankers
acceptances containing similar language,
e. g@- T h i s acceptance arises f r o m t h e
domestic storage o f cotton a n d was
secured a t t i m e o f a c c e p t a n c e

b y docu-

ments securing a n d conveying title t o ---bales a n d will remain s o secured through-

out the life o f this acceptance."
Covernor T a l l e y . I

ginning that,

would l i k e t o s a y i n t h e b e -

i n view o f the fact that w e have h a d this

supreme court ruling d o w n i n Texas,
cern

t o u s thank t h e i n t e r e s t

i t i s o f more con-

w e have been able

t o


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erouse i n the cther districts, b u t the indications o r e
thet i t i s a matter o f concern t o the other districts.
The copic "that I have p u t o n the program o f course mentions t h e supreme court ruling with reference t o the opinion

of non-negotisbility o f trade acceptances, b u t that i s
more o r l e s s incidental.

O u r counsel h a s g i v e n m e a n

epinion that h e has a right serious doubt e s t o the negotisbility o f bankers accaptances o f this character,
covering t h e domestic storage o f cotton a n d other commodities e n d secured a t the time o f acceptance b y documents
piving title t o the commodity a n d will remein s o secured
throughout t h e l i f e o f t h e acceptance.

I have sent a copy o f his copinton t o the other
banks a n d I think I have t w o opinions f r o m t w o o f the
benks which, w i t h ©11 due. respect t o their counsel, s e e m


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a0 2
to t r y t o e v a d e t h e q u e s t i o n r a t h e r t h a n t o s o l v e i t .
Briefly, I

have a s u g g e s t i o n h e r e , i r r e s p e c t i v e

opinion o f counsel, t h a t might bring a

o f the

solution toe it,

pretty much a s w e changed t h e wording o f the trade
acceptance.
fhe OhatriianicyGovernor T a l l e y , t s n ' t t h i s r e a l l y

a legal question which has g e t t o b e referred t o counsel?
Governer Talley. I

would b e glad t e refer i t t o

the Committee o n Acceptances, ocr something o f that kind.
Governor Bailey.

I s there a movement o n font t o

have a meeting e f all o f the banks! counsel? The Chairman.

I t was understord a t one time that

that meeting would occur abcut once a year. Mr. Wyatt
spoke t o m e about i t d a y before yesterday a n d asked i f
there w a s a n y d e s i r e f o r s u c h a

meeting, h e c a u s e

thought i t would b e very helpful.

he

I f such a meeting

would b e held, t w o o r three questions o n this program
and some other matters w h i c h are pending before t h e
System could well b e referred t o that meeting.
Geverner B a i l e y .

T h i s i s o n e o f them.

The Chairman. T h i s i s ene c f them.
Governor Talley. I

t h i n f r o m time t e time w e have


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accumulated some legal questions t h e t i t might n o t
be
amiss t h a t t h e y have a conference t o arrive a t
some
uniformity a s t e some o f these questions.
The Chairman. W e l l , there a r e three o r four
cases n o w t h e t I

know of. T h e r e i s t h i s e n e w h i c h y o u

raise about t h e negotiability o f the acceptance.
There i s t h e q u e s t i o n o f t h e d e c i s i o n o f t h e s u p r e m e

court o f Kansas i n Colorada &

Southern Railroad Com-

pany versus t h e receiver o f the American State Bank,
which came up. T h e r e i s still t h e Open, unsettled
case o f the state b a n k o f Huge. T h e r e i s the case
that i s n o w about t a come u p i n Atlanta o f the pract-

ice now adopted o f putting o n checks: "Payable i n New

York exchange," and having the customers o f banks draw
them o n themselves payable a t banks where t h e y carry
their account.
Governor Wellborn,

That is a

n e w departure,

that

last mentioned draft.
The Chairman. Y e s .

T h e r e are a

ions o f t h a t s o r t w h e r e I

number

o f quest~

would l i k e v e r y w e l l t o s e e a

meeting o f the counsel yeld.
Governor Bailey H a w will w e d o that, t h a t this


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Conference recommends t h a t t h e Board call a
When i t i s t i m e t o d o that, I

meeting?

would l i k e t o m a k e t h i s

motion.
The Chairman. I
these questions,

do not feel competent

t o discuss

w h i c h a r e strictly questions

o f law,

and which will affect a l l the Federal reserve banks.
I would really feel more comfortable i f w e could have

another meeting with the counsel o f the reserve banks.
Governor Harding. I
Mr. Wade,

have a

letter f r o m cur counsel,

o n the subject c f this Texas decision, a n d I

would like t o hand i t i n t e the Secretary.
The Chairman.

W h a t i s y e u r pleasure, g e n t l e m e n ?

Governor Norris. I
The Chairman.

second Gevernor Bailey's motion.

I s there a n y discussion?

A r e you

ready f o r t h e q u e s t i o n ?

Governor Talley. I

would like t o add t o it, f o r a

meeting a t a n early date.
The Chairman.

T h e amendment i s accepted b y the pro-

poser.
Governor Norris.
should c o n t a i n a

A n d then I think t h e request

statement

o f s o m e o f t h o questions.


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10D
Perhaps t h e r e a r e s o m e a d d i t i o n a l o n e s t o t h e s e t h a t

have already been mentioned this afternoon.
Governor Bailey.

W e might say, i n view o f the fact

that there a r e certain legal questions pending that a r e
of interest t a the entire System,
well t o c a l l t h e c o u n s e l

w e believe i t would b e

i n e a c h b a n k together,

a n d see

if they cannot i r o n them cut.
The Chairman,

T h e n I weuld propose that t h e resolu-

tion b e a s offered b y Governor Bailey a n d amended b y
Governor Talley, t h a t t h e Conference recommend t o t h e

Federal Reserve Board that arrangements sheuld b e made
at a reasonably early date f o r a meeting o f the counsel
and
of the Federal reserve banks/of t h e System, M r . Baker a s
special counsel, a n d that t h e Secretary b e {instructed t o
submit t o the Board a list o f these legal questions n o w
pending,

a n d i n the notice

t o t h e reserve banks

o f the

action taken that e a c h reserve b a n k b e asked t o take u p
with t h e i r r e s p e c t i v e c o u n s e l a n y q u e s t i o n s w h i c h t h e y

think should b e submitted t o that meeting.
Governor Bailey. F o r h i m t o bring o n t o this meeting?
The Chairman. F o r h i m t o bring o n t e this conference.
Governor Talley.

O f course, t h a t will include t h e


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Federal Reserve Bank of St. Louis

counsel

o f t h e Board, t o o ?

The Chairman. M r . Baker a n d Mr. “Wyatt.
Governor Talley. M r . Chairman, I
attention

t e one point

would like t o call

i n connection w i t h this question

I raised w h i c h r a t h e r e m p h a s i z e s i t s severity,

a n d that

is I would like t o recall that the regulaticns o f the
Board d o not specify t h e character o f certificate o f
eligibility, b u t i t has left i t t o a form o f certificate
that would b e satisfactory t o a Federal reserve bank,
and the Federal reserve banks, a s a matter o f uniformity,
have adopted t h e certificate n o w i n use.
The Chairman. N o t t h e o n e i n Texas.

N o t the one

complained o f i n this case.

Governor Talley. T h e one o f the bankers acceptance,

The Chairman.

W e l l , t h e f o r m o f acceptance w h i c h

was t h e subject o f the litigation i n Texas i s net t h e
form which was adopted b y the Conference.
Governor Talley. N o » I , d i d n e t mean t e s a y that.
I a m referring n o w t o t h e fact that t h e eligibility which
appears

on a

bankers a c c e p t a n c e r e g a r d i n g t h e s t o r a g e

transaction, t h e r e i s nething s a i d i n the regulations


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Federal Reserve Bank of St. Louis

about t h e form.
The Chairman.

N o .

Governor Talley.

T h e reguletions state the Gligi-

bility a s follows:

"Evidence o f eligibility and requirement o f statements.-~/ federal reserve bank shall take such
steps a s i t deems necessary t o satisfy itself a s t o

the eligibility o f the draft, bill, o r trede acceptance offered f o r discount a n d m e y require a

recent

financial statement o f one o r more perties t o the

instrument. T h e draft, bill, o r trade acceptence
offered for discount a n d may require a recent financial stetement o f one o r more parties t o the

instrument. The draft, bill, o r trade acceptance
should b e drawn s o a s t o evidence t h e character o f

the underlying transection, b u t i f i t 1s not s o drawn
evidence o f eligibility may consist o f a stamp o r certificate affixed b y the ecceptor o r drawer i n a form

satisfactory t o the Federal reserve bank.”
From the above i t will b e observed that the Federal
Reserve Board does n o t define b y regulation t h e f o r m o r
character o f a stamp o r certificate affixed b y the acceptor

107-a
or drawer f r o m which eligibility m a y b e reedily determined
but lesves a u c h form o f stemp

o r certificate t o b e s o

affixed t o one that will b e satisfactory t o 9 Federal reserve bank.

T h e present f o r m o f certificate o r stemp i n

usé o n benkers acceptances covering t h e storege o f readily
marke¥Yable s t a p l e s a n d c o v e r i n g import. and e x p o r t t r e n s -

actions,

i s one o f uniform adoption b y the twelve Federal

reserve benks a s being heretofore satisfactory t o each.
It n o w appeers i f this Conference i s impressed i n eny way
with the weight o f e n y edverse opinion o f a n y Federel R e -

serve Bank's Counsel, o r is impressed with the doubt o r
certainty f r o m a consideration o f s summery o f 311 t h e
opinions, t h e n the Conference cleerly hes t h e right t o adopt
a definite f o r m o f certificate o r t o omit t h e certificate

sltogether upon its own motion without controverting o r
violating any provision o f the Board's regulation.
For o u r o w n part, w e favor t h e elimination f r o m the

certificate o f the following language:

" x »xsand will remain

so secured throughout the life o f this acceptance.”


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Federal Reserve Bank of St. Louis

108
The Chairman. W e l l , Governor Talley,

i n the cage

of a n acceptance w h e r e t h e f o r m o f a c c e p t a n c e

i s the

legend which makes t h e acceptance non-negotiable,

no

legend added b y the bank t e assure y o u e r eligibility
would cure that bill o f its non-negotiable character.
Governor Talley. T h a t i s just t h e peint I

a m making.

The Chairman, Therefore, i n this particular case
in Texas, what i s needed i s a legend which will pass the
test o f the courts a s t o negotiability. I s n ' t that i t ?
Governor Talley. T h a t i s it.
The Chairman.

T h e n y o u have a bill o n which t h e

member b a n k will affix t h e other legend, w h i c h will satisfy y o u that i t i s e bill which i s drawn i n good faith,
and s o on,

Governor Talley.

A n d our position i s that i n view

of that ruling and o f the likelihood that the same court
will held t h e bankers acceptance w i t h this legend o n i t
nen-negotiable,

w e are having transactions a l l t h e time

in bankers acceptances t h a t float across state lines.

Some o f them originate i n my district and seme i n other
districts.

The Chairman. T h a t has got t o go before counsel,


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Federal Reserve Bank of St. Louis

109
and your counsel i s acquainted with this.

G i v e him

all the data a n d i t will result i n some discussion a n d
advice, I

hope.

Are y o u ready f o r t h e question o n the motion?

(The motion was put and unanimeusly carried.)
The Chairman.

T h i s will alse cover Topic 1 .

Governor Talley. T h e point involved there seems t o
be a

question o f t h e treation o f a

trust relationship.

Governor Bailey. Y e s } a n d we have cut i t out from
our letters that w e send out.

ion and remittance.”

W e just say "For collect-

W e do not say "In Kansas City ex-

change."
Governor Talley.

W e cover that right specifically

in cur colleetion citenlar,
Governor Bailey. I

de not k n o w h o w y o u c a n make

the collection circular override a

decision o f the court.

We are not taking a n y chance o n it, a n d that i s the
reason I

would like t o get this Conference t o pass u p e n

it, b e c a u s e t h i s i s v e r y i m p o r t a n t

t o u s o u t there,

and

we have g o t t h e m broken i n s o that t h e y d o remit i n
Kansas C i t y exchange anyhow.

T h e r e was a

case o u t there

which got through t h e courts without u s knowing anything


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Federal Reserve Bank of St. Louis

110
about it, o u r attorney never k n e w o f it, a n d all o f

these forms were not brought i n at all, a n d i t was decided t h a t way.

The Chairman.

C a n y o u take a n appeal f r o m that?

Governor Bailey.

I t i s too late.

Gevernor Norris.

I t i s through t h e supreme court.

Governor Bailey. Yes. T h a t i s the supreme court. I
de n o t k n o w w h e t h e r

w e could a s k for a

new hearing o r

not.
Governer Talley. I

think w e cught t e refer t o this

conference o f counsel a l l o f these reports w e n e getting from Mr, Baker o n the matter o f procedure, a n d i t

can advise u s i f what w e are doing o n our collections
is ali right.

The Chairman. T p a t i s just the ebject p f the
proposal f o r a report.

Y o u know when Mr. Beker w a s

present the question was raised whether inadvertently
we were not traveling close t o some other pitfalls,
and i t w a s u n d e r s t o o d t h a t w e w e r e t o p r e p a r e a

report

en all the details o f our practices i n handling collect-~ion matters,

a n d t h e n w e started t o prepare s u c h a

re-

port a n d I think i t has b e e n sent t o the other reserve


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lil
banks,

s c that b y following o n e o r the cther f o r m w e c a n

get uniformity.
Governor Talley. I

think t h e C o m m i t t e e

o n Collect-

fons h a s m a d e t h e S a n F r a n c i s c o r e p o r t t h e model.

Governor Norris. Yes.
The Chairman.

W e sent i t t o the Committee o n Col-

lections because i t was really their jeb.
Governor Fancher.

T h e chairman o f the committee

submitted your repert a n d o n e from t h e S a n Francisco bank,
and h e rather thought t h a t t h e S a n Francisco report w a s
the o n e which might b e followed b y the other banks.
Gevernor Norris. Now, w e come t o the Strong Stabilization Bill.
The Chairman. G e n t l e m e n , I

will s u g g e s t t h a t w e

make this t h e last topic a n d excuse t h e stenographers f o r
the afterneon a n d have this i n executive session.
(Whereupon,

a t 5 . 1 0 Pem., t h e C o n f e r e n c e w e n t

into executive session, a f t e r which a n adjournment w a s t a k e n u n t i l t o m o r r o w , T h u r s d a y ,

November 3, 1927, a t 10 otclock a.m.)


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Federal Reserve Bank of St. Louis

SECOND DAY.
A CONFERENCE O F GOVERNORS O F THE FEDFRAL
RESERVE BANKS.

ereasury Bulicing,
Washington, D . C.,
Thursday, N o v e m b e r 3 , 1927.

The C o n f e r e n c e

o f Governors

o f t h e Federal Reserve

Banks convened i n the Hearing Room o f the Federal Reserve Board, Treasury Building, Washington, D . C., a t
10 o'clock a.m., Thursdey, November 3 , 1927, pursuant
te adjcurnment o f yesterday.
APPEARANCES ;
AS i n d i c a t e d ’ n
i the first day's proceedings.

The Chairman, G e n t l e m e n ,
to order. I

have h e r e a

t h e meeting will kindly come

set o f t h e reports

o f the sub-

commitvee o f the General Acceptance Committee o f the Federal Reserve Board, made following the meeting held i n
New Y o r k a n d a

conference w i t h t h e officers, v i c e - p r e s i -


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Federal Reserve Bank of St. Louis

113
dents,of a l l t h e banks t h a t accept there, w h i c h report
contains t h e substance o f recommendations w h i c h have
been preposed a

number o f times t o liberalize o n e o r

two o f the rulings o f the Federal Reserve Board a s t o
acceptance credits.

G e v e r n e r Young has just handed

this t o me, w i t h t h e suggestion that this c a n b e considered a n d then commented upon, a n d that t h e Board will
thereafter t a k e action right away.
I also have a

rough draft o f regulation K , series o f

1927, relating t o the collection c f maturing notes a n d

bills. T h i s brings u p that old bird "ncen-cash collectione<"

T h i s i s t o b e distributed alse, Mr. Harrison.

After t h e t h a s b e e n read, p e s s i b l y a t a

maybe I

can suggest a

later session,

method o f dealing w i t h it. I

will

try to, anyway.
The l a s t r e g u l a t i o n n o w u n d e r c o n s i d e r a t i o n

regulatian D . I

is

have also b e e n handed tentative draft,

which w a s a p p r o v e d

b y t h e Federal Reserve B o a r d J u n e 2l,

1927. Accompanying that is a suggested alternative substitute o f Section 2-D, prepared b y the Board's counsel,
and t h e f i n a l d r a f t

of regulation D

n a w before

t h e Federal Reserve

Board

is the last draft submitted b y their


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114
counsel.
set,

I

t takes o n e o f e a c h o f t h e s e t o m a k e a

s o that w e c a n consider t h e proposed r e v i s i o n o f

the r e g u l a t i o n a s n o w b e f o r e t h e R e s e r v e Board.

This i s the impertant regulation having t c d o with
the reserve a n d deals w i t h the question c f window dressing,
that is, t h e weekly a n d bi-weekly reports o f reserves i n
the cities where there a r e branches, a n d the Board would
like t o have t h e Conference g i v e expression c f views o n
that, a l l o f w h i c h I

think w e s h o u l d t a k e u p tomorrow,

after w e have h a d a chance t o read these matters.
In t h e a b s e n c e o f t h e c h a i r m a n o f t h e A d v i s o r y Come-

mittee o f the Conference o n Legislative matters, suppose
we t u r n t e t h e s e c o n d g r o u p o f topics,

the Standing Committee o n Collections.

A , Report o f

I s Mr. Strater

available?
Geverner Fancher. M r . Strater i s here, M r . Chairman.
The Chairman. B e f o r e t a k i n g t h a t u p , y e u w i l l b e i n -

terested t o know that Mr. Newten D . Baker i s i n New York.

I had hir o n the telephone this morning and h e will
likely b e here this afternoon, n o t with t h e idea o f attending t o any business, b u t I told h i m that w e were a l l
here a n d I theught that everybody would b e glad t o see


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Federal Reserve Bank of St. Louis

115
him i f h e was i n the building.

H e said h e would proba~

bly b e i n the building some time this afternoon.
Governor McDougal. I

understood that Mr. Baker

was t o discuss this topic 2 - B with t h e Conference.
The Chairman. I
Governor Fancher.

did not know about that.
H e d i d not s o understand it.

Coming d o w n c n the train Monday I

asked h i m i f h e expeot-

ed t o a t t e n d t h e C o n f e r e n c e a n d h a v e a

discussion o f a n y

topic w i t h u s , a n d h e s a i d t h a t h e d i d n o t s o u n d e r s t a n d

Gx

The Chairman (after discussion). W i t h o u t dissent,
it i s agreed that Topic II-B, Nos. 1 , 2 and 3 , will b e referred t o the meeting o f counsel o f the Federal reserve

banks. I

have mentioned that matter t o Governer Young

and, expressing h i s personal view, h e said h e thought i t
would b e a good plan t o have s u c h a meeting.
We w i l l n o w t a k e u p T o p i c @ £ - C .

II. C o l l e c t i o n s a n d Clearings.
C. Duties a n d liabilities o f Federal r e -

serve banks with regard t o shipments
of cancelled Government warrants a n d
checks.
Governor Talley.

M e m b e r s o f this Conference a r e

of course familiar w i t h the procedure o f paying Government


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Federal Reserve Bank of St. Louis

Li6
checks, a r r a n g e d

i n schedule form, a c c o r d i n g

t o the

requirements o f the Treasury, a n d sending t h e m
to
Washington f o r credit.

I f any o f those checks were

lost, i t would create a good deal o f inconvenience, i f
not some embarrassment.

T h e y r u n into very large amounts

and v a r y i n character,

I

t seems t o u s that s o m e sort

of accommedation ought t o b e reached with t h e Treasury

as t o just what our duty i s and what our liability might
be.

W e have made a n arrangement--I d o not know whether

it has been extended t o the other banks o r not--but would
be o n request,

n o doubt--with

insure these warrants, I

a n insurance c o m p a n y t o

think f o r 1 0 per cent o f the

face amount,

t a caver a n y expense

of interest,

o r obtaining o f duplicates, a n d s o forth.

i n connection w i t h loss

I have a memorandum from m y counsel which I would like t o
read.

"The warrants being cancelled and e f no value
other t h a n f r o m a n a c c o u n t i n g s t a n d p o i n t ,
lon a r o s e a s t o whether

t h e quest-~

o r not a n y s u m would h e re-

coverable f r o m t h e insurance company without t h e
policy expressly s o providing.

W i t h this point i n

view Mr. S w a n s u g g e s t e d t h a t t h e p o l i c y h a v e a t t a c h e d


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to i t a rider reading substantially a s follows:

"'It is agreed that securities, bank checks
or commercial paper that i s not negotiable i n
form m a y b e i n s u r e d f o r n o t l e s s t h a n t e n p e r
cent o f t h e i r f a c e amount.

I n case o f l o s s o f a n y

such shipment t h e assured shall b e indemnified
for t h e total cost o f procuring t h e reissue o f
the property insured, including t h e legal a n d
advertising expenses, l o s s o f interest a n d all
charges directly resulting f r o m t h e loss e r from
the d e l a y i n replacement,

s u c h total c o s t n o t

to exceed t h e amount o f insurance.!

"We think the rider suggested i s sufficiently
broad t e cover t h e purpeses desired. H o w e v e r ,
occurs

t o us that a

it

much b r o a d e r q u e s t i o n t h a n t h a t

of insurance h a s b e e n raised a n d w e are writing y o u
with reference t o the matter i n order t o get your
views.

"We heve consistently taken the position that,
in t h e p a y m e n t

o f Government warrants a n d checks

under t h e i n s t r u c t i o n s

o f t h e T r e a s u r y Department,

we are acting mercly a s a n agent i n the performance
of ministerial duties. W i t h this peint i n mind


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Federal Reserve Bank of St. Louis

118
the Treasury Department w a s induced, s o m e time aga,
to reverse t h e pesition that i t had formerly taken
with reference t o its right t o arbitrarily charge
back G o v e r n m e n t w a r r a n t s w h i c h u p o n i n v e s t i g a t i o n

proved t o b e forgeries.

“While the Treasury's instructions a t this time
permit t h e various Federal Reserve Banks t o charge
the a m o u n t o f G o v e r n m e n t w a r r a n t s p a i d u n d e r s u c h

instructions

t o the account o f the Secretary o f the

Treasury, this charge is not fully acquiesced i n by
the Treasury Department until t h e instruments s o

paid have reache, Washington and have been inspected.
As f a r a s w e k n o w t h e r e h a s n e v e r b e e n a
transit

o f s u c h shipments,

loss i n

b u t t h e question occurs

to u s t h a t i n t h e e v e n t t h e r e s h o u l d b e a

loss o f

a substantial amcunt o f these instruments between

Dallas and Washington, what would b e the status
of the charge, under the present practices, which
the Federal Reserve Bank o f Dallas has made because
of the payment o f these warrants.

I n ot*er words,

would the Treasury Department permit the charge
to s t a n d sheculd t h e F e d e r a l r e s e r v e b a n k b e u n a b l e


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Federal Reserve Bank of St. Louis

19
to p r o c u r e d u p l i c a t e i n s t r u m e n t s a n d e n d e r s e m e n t s ?

In the event o f a large shipment i t i s entirely possible that t h e payee a n d endorser o f many o f these
knstruments c o u l d n e v e r

b e lacated a n d t h e questicn

would arise a s t o what would b e t h e status o f the
charge representing these ameunts.

"We are o f the opinion that, i n view o f the fact
that Federal reserve banks a r e acting a s fiscal
agents i n the payment o f these obligations, t h e

Treasury Department should give explicit instructions
as t o h o w they wanted shipments m a d e a n d that w h e n
a Federal reserve b a n k had followed these instructions
its d u t i e s w o u l d h a v e b e e n d i s c h a r g e d a n d i n t h e

event o f loss t h e charge would b e final a s between
the Federal reserve b a n k a n d the Treasury Department.

O

f course, t h e r e i s n o o b j e c t i o n

as t h e F e d e r a l R e s e r v e B a n k o f Dallas
to d e f r a y i n g t h e c o s t o f i n s u r a n c e
Department c a r e s

i n s o far

i s eencerned

i f the Treasury

t o have t h e s a m e t a k e n o u t i n

reasonable ameunts n o r i s there a n y cbjection t o
lending every effort i n the case o f loss t o secure
the execution o f duplicates, b u t w e think that t h e


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Federal Reserve Bank of St. Louis

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Treasury Department should require ncthing further
of the Federal reserve banks.”
Governor McDougal.

F r o m what I

have heard, I

think

the Dallas b a n k locked a t thie f r o m a different angle
than the angle f r o m which w e look a t it.
sider that w e p a y the checks a t all.

W e d o net con-

W e consider t h a t

we cash them a n d they are n o t paid until t h e y get t o
Washington.

W e never cancel them.

The Chairman.

I t i s not a question o f our power t o

construe t h e proposition.

T h e l a w o f the United States,

passed i n the days o f Alexander Hamilten, provides t h a t

no payment should b e made out of the general fund o f the
United States except i n Washington. I
exactly,

b u t t h a t i s t h e substance

do not state i t

o f it.

What w e d e i n New York i s t o prepare t h e account i n
exact f o r m asiipreseribed b y the Treasury, g i v i n g a l l the
particulars c f the check, including t h e symbols.

W e

retgin copies o f the account i n New York, a n d a copy

accompanies the shipment, o r may g o separately, I
which. I

forget

think i n one instance w e Had something l i k e

a million dellars o f transit stuff taken o u t o f a mail

sack. T h e y thought they were getting good securities,


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Federal Reserve Bank of St. Louis

J21
and they were just getting vouchers.
with the Treasury.

W e had n o trouble

I t was attended to, b u t I

remember j u s t how. I

do not

think i f t h i s m a t t e r i s t a k e n u p

with t h e Treasury Department b y any bank that h a s a n y
feeling o f uncertainty about t h e right t o maintain t h e
charge against t h e Treasury account, t h a t t h e Treasury
will give t h e m assurance, a l l t h e assurance t h e y need.
Governor Fancher. T h e thing that h a s b e e n i n m y
mind, Mr. Chairman, g c i n g b a c k t o the experience o u r bank
had some years ago, w a s t h e question o f the mail burning
up. T h a t i s the thing that gives m e concern,

i f we

should have a large batch o f these Government warrants
burned, t h e time required i n getting duplicates a n d things
of t h a t sort, w o u l d c o v e r a
lot o f correspondence,
The Chairman. I

long period, w o u l d e n t a i l a

a n d s o forth, a b o u t t h e charge.
cannot t e l l y o u a n y o f t h e d e t a i l

of what happens, b u t I think with duplicates o f the accounts i n New York, I

would n o t anticipate a n y difficulty

about t h e charge. T h a t i s m y understanding.

T h e report

I have here o n i t does n o t g o into that feature o f it,
but m e r e l y d e s c r i b e s t h e method.

Governor Harding.

H a v e a n y o f y o u looked into this


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Federal Reserve Bank of St. Louis

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arrangement f o r making films o f the Government warrants

s o that y o u c a n have photostatic copies

o f them

made?
The Chairman. P h o t o s t a t i c c o p i e s ?

Governor Harding. Yes. T h e r e was 8 man i n our
effice n e t long a g o w h o h e d a very attractive little d e vice.

I t did net take a s Icng a s keeping t h e reeecrd o f

the endorser, t h e drawer, a n d a l l that sort o f thing.

It is just a little bit o f a thing; they take them and
run them right threugh t h e machine, a n d they g e t this
film a s they g o i n the mechine.
by date.

Y o u file t h e films a w a y

I f you have a loss a n d want a phetostatic c o p y

of a n y o f t h o s e t h i n g s ,

y o u take t h e films o u t a n d send

them t o this m a n a n d h e w i l l e n l a r g e t h e m f o r you.

The Chairman.

W e sometimes p a y forty o r fifty

theusand Government checks i n a day i n New York.
Gevernor Harding.

T h i s m a n says h e i s prepared

te

handle a n y a m e u n t o f then.

The Chairman. Sometimes,

o n b i g days, w e p a y a s

many a s 6 fiillion a n d a half t o two million i n a day o f
coupons.
Governor Harding.

T h i s m a n has cffered t o give


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Federal Reserve Bank of St. Louis

123
a demenstration a n d I

a m going t o lock into i t when I

go back.
Governor Talley.

D e y o u recall w h a t happened

i n your

case i n reference t o reimbursement?

The Chairman. No, I do not remember. I

am very’ vague.

I know that a mail s a c k was slit o p e n a n d a million dollars
of c a n c e l l e q a n d m u t i l a t e d s t u f f w a s t a k e n cut.
Geverner Norris.

I f you had lest a

million d o l l a r s

you would have remembered it, Mr. Chairman.
The Chairman. I

think I would have remembered that.

But I think this c a n b e worked c u t with the Treasury,

if

there i s a n y d o u b t i n anybody's m i n d a b o u t i t .

Governor Bailey.

W e carry o u t their explicit i n -

structions telling u s how t e do it, i n order t e relieve
cur mind o f it.

B u t i f there was a n y w a y t o make a n

agreement, w h y net have t h e counsel f o r t h e Board o r our
counsél make a n agreement w i t h the Treasury that would
cover a l l o f the banks?
Governor Norris. O h , I

do not think i t i s a legal

matter.

Governor Talley.

M y idea i n b r i n g i n g t
i u p was that


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124
it teuches e v e r y bank; e v e r y b a n k h a s t h e s a m e preblem.

The Chairmay. Certainly.

D o you have a bosd eov-

ering Lt?
Governor Talley.
insuring

e a

p

e

W e put this rider o m our pelicy

r c e n t o f t h e f a c e amount.

The Chairman.

B u t your loss i s liable t o b e 100

per c e n t oar hnane.

Governor Talley. T h a t i s true.
The Chairman.

A n d 1 0 per cent would n o t help very

much.
Governor Fancher. Y o u are pre,eeding o n the theory
of t a k i n g c a r e o f i n t e r e s t f r o m i n t e r e s t c h a r g e , e x p e n s e

ofgetting duplicates, amd all that sort of thing.
Governor Talley. Yes,
Gevernor licDougal. Most o f the banks are sending their
cheeks b a c k b y mail.

W e think there i s a greater element

of securing i n using express company, a n d i t i s very
much m e r e e c o n o m i c a l

Mr. Harrison.

t o s e n d t h e m b y express.

W e da, too.

Governor Norris.

W e a l s o u s e t h e express companies.

The Chairman. O u r s a r e sent b y express.
Governor Fancher.

W e u s e t h e mail,

d o w e not, M r .


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Strater?

Mr. Strater.

W e send ours b y registered mail.

That

comes about largely because t h e Treasury insists o n getting o u r warrants t h e following d a y and w e could net g e t
them here b y express.
The Chairman.

W h a t would y o u like t o have done

about this, Governor Talley?
Governor Talley. I

would like t o get some suggesticns

and advice about it.
The Chairman.

W h i l e y o u are here, w h y don't y o u

take that u p with t h e m e n i n the Treasury that have t h e
handling o f these things, a n d report b a c k t o u s what y o u
learn f r o m them?
Governor Talley. I
The Chairman.
line o n that.

will make a n effort t o d e that.

M r . Mills will undoubtedly give y o u a

I t has just occurred

t o m e that w e have

always invited Mr. Mills t o come inte t h e meeting a t his
convenience,

t o discuss a n y T r e a s u r y m a t t e r s t h a t w e w o u l d

like t e discuss w i t h him, a n d I will appoint Mr. Talley
a cemmittee c f one t e convey thet information t o the

Under Secretary, a n d t o de i t now.

I f that will b e

satisfactory, Governor Talley i s n o w a p p c i n t e d acommittee


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of o n e b y unanimous acclaim.
The Chairman.

G o v e r n o r S e a y , h a v e a l l t h e members

of the Advisory Conmmittee o n Legislative Matters examined
and appreved t h e €hairman's report?
Governor S e a y .

Mr.Chairman,

t h e report

i s the exe

pression o f t h e v i e w s w h i c h c o m e f r o m t h e d i f f e r e n t n e m bers o f t h e A d v i s o r y C o m m i t t e e ,

w i t h t h e e x c e p t i o n o f ycur-

self.
The Chairman. I

a m for t h e report.

Governor Seay. I s the Conference r e a d y f o r m e t o
present m y report?
The Chairman. Y e s .

Report o f the Advisary Committee o n
Legislative M a t t e r s .

Governor Seay. T h e report i s a s follows:

"tDesirability of amending that part of Section
13 relating t o discount o f demand a n d sight drafts
secured b y shipping documents covering domestic shipment o f agricultural preducts s o i t will include
all staple non-perishable commodities, s u c h for
example a s flour, bran, cottonseed meal, etc., a s
well a s r e i m b u r s e m e n t d r a f t s f o r t h e p r e c e e d s

of


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Le
other bills earrying shipping documents.*

"(See paragraph 19, page 1 1 of the Secretary's Minutes.)
Subsequeatly i n the Conference ( s e e paragraph 24, page 14),
upon motion o f Governor Harding,

i t was !

"t¥oted that the Federal Reserve Board b e asked
to reconsider i t s previous ruling t o the effect

that bran, flour, cottenseed meal, etc., are nonperishable, products within t h e meaning o f Séotkee

13, i t béing pointed out that the particular paragraph i n question does n e t coatain t h e limitation

fin the raw state! a s i n the previous paragraph
of the law.

I t was understood that this action

dees n o t revoke t h e action taken Tuesday, M a y 10,

under Yopic I.G.§
"The action o f the Conference referred te, taken
Tuesday, M a y 10, w a s a reference o f the topic t o

the Advisory Committee o n Legislative Matters.
"The Beard has previously ruled upon the construction o f the term tnonperishable, readily mare
ketable agricultural products!

o n page 2 7 6 o f the

April, 1924, Bulletin, a n d page 8 5 4 o f the December,


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128

1926, Bulletin.

I n t h e light o f the ruling o f

the B o a r d i n April, 1 9 2 4 , a b o v e r e f e r r e d t o ,
wherein t h e Béaard stated:

"tThe Board i s o f the opinion, therefore, t h a t
Federal reserve banks should n o t refuse t o discount
sight o r demand bill o f lading drafts mezely because
the agricultural products covered thereby a r e n o
longer i n a téchnically r a w state, b u t have passed

through the initial stages o f refinement o r pro-

cessifig subsequent t o their actual harvest?;
"and i n view o f the wording o f the present law, 1 ¢
is b e l i e v e d t h a t t h e B e a r d h a s t h e p o w e r

t o make

a ruling sufficiently broad te meet the legitimate
demand f d r t h e d i s c o u n t

o f sight a r d demand drafts

secured b y shipping documents covering agricultural
products,

a s deseribeda i n t h e t o p i c r e f e r r e d

Advisory Committee for consideration.

t a the

I t is not

belfeved to be necessary o r advisable a t this time
to seck a n amendment t e Sectioh 1 3 ef the Act relating t e this subject."
Now, the Beard, i n the opinion rendered i n 1924,
stated t h a t a

Federal reserve

b a n k should n o t refuse

t o


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Leo
Ciscount sight o r deisand oi11 c f lading drafts, b u t
they have somewhat modified their pesition, a n d i n the
opinion o f members o f the committee,

a s I gathered i t

by correspondence, t h e r e i s nothing i n the present l a w
which would prohibit t h e Beard from meking t h e ruling
sufficiently b r o a d t e c o v e r t h e n e c e s s i t i e s

o f the trade

in the matter.
The Chairman: T h e r e i s a little difficulty there.
Apparently t h a t r u l i n g o f t h e B o a r d m a d e i n December,

1926, i s based,

o r was based, o n the decisien o f the

Supreme Court o f the United States i n the case o f Getty
against C . R. Barnes Miliing Company,

i n which i t was held

thet flour w a s n o t e n agricultural preduct. I

neverthe-

less apvreve o f this report c f Gevernor Seay's, because
the e n t i r e m e t h o d o f d e a l i n g w i t h t h a t i n v e l v e s

a n act

ef Congress, a n d none c f u s want t e g e before Congress
for a n y emendment j u s t now.

Gevernor Seay.

T h e ruling c f the Board i n 1926 was

something o f a reversal o f a previous ruling o f the Board,
but t h e o p i n i o n i s t h a t t h e r e i s n e r e a s o n i n t h e l a w w h y

the Board might n e t revertte i t s former decision.
The Chairman. T p a t i s = recommendatica o f the report,


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is i t not?
Governor Seay. T h a t i s the recommendation o f the report.

The Chairman.

I s there a n y further discussion o f this

report?
Governor Bailey. I
Governor Seay.

would like t o ask “question o f

D o you know w h y thi8 td: that under t h e

McFadden A c t a man c a n loan-25 per-cent o f his profit a n d
surplus o n paper properly s e c u r e d , t
u
b they c a n only rediscount 1 0 per cent.
Governor Seay.

T h a t i
s the l a w with us..

I t always h a s been.

Governer Bailey.

B u t i f they a r e permitted t o loan

25 per cent, ‘why should n o t t h e l a w b e corrected? I
think t h e M c F a d d e n A c t d i d n o t g c f a r e n o u g h a n d d i d
net m e e t t h a t s p e c i a l point.

W h y should t h e y not b e

permitted t o rediscount w i t h u s 2 5 per cent o n a prop-

erly secured note?
Governor Seay. I t could be, but for myself I hope
it never will be.:

Geverner Bailey. W h y ?
Gevernor Seay. W e l l , f o r o n e thing, w e d o not want
to take; a n d w e d o n e t take,

a s a. matter

o f practice,


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151
the entire l i n e discounted b y a n y member b a n k f o r
any
particular c u s t o m e r ,

a n d w e d e n o t w a n t t e d o that.

We take a reasonable amount of it.
Gevernor Bailey.

B u t i f the note i s absolutely s e -

cured f o r 1 0 p e r c e n t a n d i s a

geod note, t h e n i t i s g o o d

for 2 5 per cent,.and i t works a

hardship o n chose fellows

out there,
The Chairman...

B u t when t h e nete i s good a n d y o u

only take 1 0 per cent o f it, eof course y o u dontt l o s e s o

much.
Governor B a i l e y . I

have y e t t o s e e t h e f i r s t

cattle feeder l o a n which f s net good.
Gevernor Seay- S i n c e y o u a s k m e the question,

Governor Batley, i t i s a question c f « fundamental policy
ef the System. I

dare say i t can be done, but person-

ally I weuld not like t o see i t dene.
The Chairman. W e l l , this i s a digression from the
report

o f G e v e r n o r Seay.

discussion o f it.

abeut this repart?

T h e r e seems

W h a t i s t h e nleasure

t o b e n o further
e f t h e Conference

T h e report contains a

recommenda-

tion and tne adoption o f the report will inciude endorsement

o f t h e recommendation.


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132
Governor Fancher. I

move that t h e report b e

adopted.

Governor Wellborn, S e c o n d e d ,

{The motion, having been duly seconded, was unanimously carried.)
The Chairman. Now, Mr. Strater,

w e will have t h e

report o f the Standing Cammittee o n Collections.
II. C o l l e c t i o n s a n d Clearings.
A. R e p o r t o f Standing Committee o n
Collections.
Mr, Strater.

M r . Chairman a n d gentlemen, t h e

Standing Committee o n Collections b e g s t o submit herewith its report o n the following topics:
"Revision o f time schedules w i t h a view
to reducing float a n d aveiding existing
inequalities.

"At the Conference o f Governors held i n
November, 1925, i t was voted t o request the Stand-:
ing C o m m i t t e e

o n Collections

t o make a

study o f

the p r e s e n t t i m e s c h e d u l e s a n d p r e p a r e a

scientific

revision o f t h e m i f t h a t s h o u l d b e necessary.

I t

was understocd that t h e Committee should consult o r
advise with a n y o f the Federal reserve banks, when-

ever i t might b e helpful fer the Committee t o d o


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133
so, a n d that tentative schedules b e submitted t o
each b a n k f o r r e v i e w b e f o r e a n y f i n a l s c h e d u l e s

were submitted toa the Conference.

"In this Committee's report t o the November,
1926, Conference o f Governors,

i t expressed i t s

opinion a s t e how a scientific a n d accurate time
schedule s h e c u l d e
b constructed ‘ n order t o extend
the benefits o f the check collection system equis+
tably a n d i m p a r t i a l l y

t o all member banks a n d a t

the s a m e t i m e r e d u c e f l o a t t o t h e l o w e s t p o s s i b l e

point consistent w i t h expediency o f operation, w h i c h
epinien i t deems advisable t o repeat. T h e logical
and scientific basis f o r a n accurate intra-district
time s c h e d u l e m u s t b e t h e a v e r a g e t i m e r e q u i r e d

by

each Federal reserve b a n k t o ecllect checks payable
in each state o r part o f state within i t s o w district, a n d the logical a n d scientific basis f o r
an a c c u r a t e i n t e r - d i s t r i c t t i m e s c h e d u l e m u s t b e
the t i m e r e q u i r e d

t e reach t h e Federal reserve

bank o r b r a n c h o f t h e d i s t r i c t

i n which t h e checks

are p a y a b l e s l u s t h e d e f e r r e d t i m e g i v e n b y s u c h
Federal

reserve

bank

o r branch after

t h e checks


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Federal Reserve Bank of St. Louis

Peeen it.
"In order t o obtain accurate figures showing
the average time required b y each Federal reserve
bank a n d b r a n c h t e cecllect c h e c k s p a y a b l e
State o r p a r t o f s t a t e i n i t s territory,

i n each
t h e Com-

mittee obtained f r o m each Federal reserve b a n k a n d
branch a n analysis covering a
and, u s i n g t h i s a s a

period o f one week,

basis, p r e p a r e d a

tentative

inter-district t i m e schedule f o r each Federal r e serve b a n k and branch, copies e f which i n duplicate
were f o r w a r d e d

t o e a c h o f t h e Governors accompanied

by an interim repert explaining the manner i n which
these tentative schedules h a d been prepared, a n d requesting that t h e y b e reviewed a n d returned t o the
Committec,with s u c h corrections a s were necessary
in o r d e r t o m a k e t h e t i m e s c h e d u l e s acceptable.
When t h e c o r r e c t t i m e s c h e d u l e s w e r e r e t u r n e d
the Committee,

to

i t was f o u n d t h a t m a n y o f the minor

inequalities pointed out i n the report t o the Conference o f Governors h e l d i n March, 1926, h a d been
eliminated b y the acceptance o f the Committee's recommendations.

T h e major irregularities still exist


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135
in certain districts a n d the Committee finds i t self unable t o accomplish t h e object which i t
was directed b y the Conference t o attain.

"The Committee feels that i n the case o f
seven c f t h e F e d e r a l r e s e r v e b a n k s ,

t h e time s c h e d -

ules finally approved a r e a s accurate a s they c a n
be made, a n d t o a l l i n t e n t s a n d p u r p o s e s t h e d e f e r -

red time shown f o r checks payable i n states o r
parts o f states wholly outside o f their respective
districts,

i s the correct average t i m e required t o

collect. C e r t a i n major inequalities w h i c h existed
in the time schedules o f several o f the Federal
reserve banks w h e n t h e Committee first undertook
to m a k e a n e x h a u s t i v e s t u d y o f t i m e s c h e d u l e s s t i l l

exist, a n d believing t h a t t h e Governors w i l l b e
interested i n having t h e m peinted out, t h e y are
shown below under a

separate heading f o r e a c h o f

the five Federal reserve banks, which, f o r
reasons considered b y them t o b e expedient,

d o not

feel that they are i n a position t o accept the
Commiutee's recommendations:
"Boston.

C h e c k s d r a w n o n banks i n the


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136
states

o f Delaware,

N e w Jersey,

N e w York,

and

Pennsylvania a r e given a deferred availability o f
two days whereas i t i s physically impessible t o
collect a n y e f these items through existing channels
in less t h a n three days a n d a substéntial volume
in less t h a n four days. C h e c k s d r a w n c n country
banks i n all o f the cther states cutside o f the First
Federal Reserve District a r e given deferred availability o f either four o r eight days a n d none o f the

resulting inconsistencies have been corrected.
"A few Lllustrations will suffice: C h e c k s payable i n the state o f Arkansas a r e given a deferred
availability o f four days whereas s i x days a r e re-

quired. C h e c k s payable i n the state o f Tennessee are
given deferred availability o f four days whereas

five o r six days are required t o collect. C h e c k s
peyeble i n the state o f Oklahoma a r e given a defer-

red availability o f eight days whereas they can
readily b e callected i n five o r six.

"New York. C h e c k s payable i n all six o f the
New Ergland states a n d Delaware, District c f Columbia,
Maryland, t h a t part o f New Jersey i n the Philadelphta


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137
district P e n n s y l v a n i a , a n d Virginia a r e
given a
deferred availability o f two days whereas
they can
in n e case b e collected i n less t h a n
three through
existing channels.

A l l other minor inconsistencies

which f o r m e r l y existed, h a v e b e e n corrected.

I t

should b e noted that t h e tine schedule o f
the Buffalo
Branch does n o t contain t h e inconsistencies
which
are pointed o u t i n the schedule o f the parent
bank,
except t h a t c h e c k s d r a w n o n points

i n that p a r t

of t h e s t a t e o f N e w J e r s e y w h i c h i s i n t h e
Phila-

delphia district a r e given a deferred availability
of two days whereas a t least three davs a r e re-~
quired t e collect.

"Philadelphia. C p e c k s payable i n all six
of t h e N e w E n g l a n d states,
Maryland,

a n d District

o f Columbia,

t h a t part o f N e w Jersey i n the N e w York

district, N e w York, t h a t part o f Pennsylvania
in

the Cleveland district, a n d Virginia are
given
a deferred availability o f twe days whereas
i n no
case c a n they b e collected i n less t h a n three.

All

other inconsistencies h a v e b e e n corrected.

"Chicago. C h e c k s drawn o n points i n those


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133
parts o f t h e s t a t e s

o f Illineis a n d Indiana w h i c h

are i n t h e S t . L o u i s d i s t r i c t a n d t h a t p a r t o f t h e
state o f W i s c o n s i n w h i c h i s i n t h e M i n n e a p o l i s d i s -

trict, a r e given a

deferred availability o f two

days whereas t h e actual time required f o r collection
is not less t h a n three days.

I n order that scien-

tifically c o r r e c t t i m e s c h e d u l e s m a y b e constructed,
the C o m m i t t e e b e l i e v e s t h a t i t i s n e c e s s a r y

to

consider parts o f states lying outside o f a Federal
reserve district o n the same basis a s though t h e y
were s e p a r a t e s t a t e s w h e n e v e r t h e v o l u m e

i s of

material size.

"Kansas City. Checks drawn o n points i n that
part o f the state, o f Misseuri outside o f the Tenth
Federal Reserve district, a r e given deferred availaobility o f two days whereas three days a r e required
for collection.

“Pabulations, showing the time schedules which
each bank will agree t o adopt b u t which still centain
in the case o f five banks t h e inconsistencies
inequalities described above, a r e attached t o
made a part o f this report a s follows:


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Federal Reserve Bank of St. Louis

139
"(1) T i m e schedules showing deferred availability given b y each Federal reserve b a n k a n d
branch for checks payable i n cther Federal reserve
bank a n d b r a n c h cities;

and

"(2) T i m e schedule showing deferred availability given b y each Federal reserve b a n k a n d branch
for. checks payable i n states o r parts o f states
wholly cutside o f their respective districts.

"With respect t o item (1) the Committee i s of
the opinion that the deferred availability given
in e a c h i n s t a n c e

i s accurate, a n d ,

i f adopted b y

the Cenference a n d each o f the Federal reserve
banks concerned, w i l l result i n a n almost entire
elimination o f float o n this class o f items a s between Federal reserve b a n k a n d branch cities.
With respect t o item (2) a l l that h a s b e e n expressed i n this report applies, a n d the Committee
desirés t o again state that this particular schedule

4s not scientifically accurate a n d that the inaccuracies contained therein, w i l l result i n the creation o f a considerable volume o f float which must
be c a r r i e d b y t h e F e d e r a l R e s e r v e System.


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"Having presented to the Conference the result
of its investigations a n d efforts, a n d believing
that t h e Conmittee c a n make n o further progress i n
this connection,

b o t h schedules a r e submitted with-

out a n y specific recommendation.

"A study o f the whole question
of t h e c o l l e c t i o n o f c a s h items.

"The Conference o f Governors o f November,
1926, voted t o request t h e Standing Committee c n

Collections t e continue its study o f the collection
problem, having i n mind particularly whether a
Federal reserve b a n k m a y not shorten t h e actual
transit t i m e b y sending direct t o member banks
located

i n o t h e r d i s t r i c t s u n d e r crprangements w i t h

the Federal reserve banks o f those districts, a n d
4 £s
to consider also what, i f any, modifications
or

improvements might b e made i n order t o effect a
better a n d m o r e s c i e n t i f i c c o l l e c t i o n system.

"In the Committee's report t o the Conference
cf Gevernors c f May, 1927, a brief resume o f the
Committee's a c t i v i t i e s

i n this connection w a s pre-

ince t h a t Conference,

e a c h o f the Federal


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Federal Reserve Bank of St. Louis

141
reserve b a n k s h a s b e e n r e q u e s t e d

t o furnish t h e

Committee w i t h its ideas a s t o what change would
best t e n d t o improve t h e collection machinery. M o s t
of the banks have r e p l i e d o
t the Committee's request
and t h e consensus o f opinion appears t o b e that t h e
direct routing o f checks i n t o other districts m a y
tend t o reduce t h e collection time b u t that s u c h a
practi¢ée i s not altogether desirable i n every instance.

"In the opinion o f the Committee, inequalities
and inconsistencies appearing i n the existing time
schedules o f a number o f the Federal reserve banks
are very closely connected w i t h the subject o f d i r e c t
routing b y Federal reserve banks i n t o other districts..
It i s quite ecbvious that s u c h a n arrangement c a n not
be made without t h e consent o f the paying bank inasmuch a s under t h e Federal Reserve A c t a n d Regulation J
of the Federal Reserve Beard, t h e nermal channel
of c o l l e c t i o n i s t h r o u g h t h e F e d e r a l r e s e r v e b a n k
of t h e d i s t r i c t

i n w h i c h t h e c h e c k s a r e payable.

I f

the time schedule o f the bank s o attempting t o
collect c h e c k s p a y a b l e

i n other districts

i s based


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Federal Reserve Bank of St. Louis

142
upon t h e time required t o collect through t h e Federal reserve b a n k o f the district i n which t h e
paying b a n k i s located,

t h e paying b a n k may b e the

duced t o a g r e e toa s u c h a n a r r a n g e m e n t p r o v i d e d i t s
checks a r e g i v e n f r e e r c u r r e n c y b y r e d u c i n g t h e d e ferred t i m e o n t h e t i m e s c h e d u l e

c f t h e Federal r e -

serve b a n k attempting t o make s u c h a n arrangement.
"Tf the deferred availability o n checks payable
in any considerable a r e a immediately adjoining a
given F e d e r a l r e s e r v e d i s t r i c t

i s a t present equiva-

lent t o the time required toe collect b y direct routing, t h e m e m b e r

o r non-member b a n k w i t h which a

direct routing arrangement i s sought m a y be induced
to agree t o such a n arrangement i f it 1s pointed out
that unless a

majorityf
o the banks i n such ad-

joining territory agree t o a direct routing arrangement, i t will b e necessary t o increase t h e period o f
deferred a v a i l a b i l i t y toc c o r r e s p e n d w i t h t h e a c t u a l

methed c f collection.
"The Cemmittee i s o f the opinion that t h e
practice o f a Federal reserve b a n k sending direct

to member banks, a n d possibly t e non-member banks,


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Federal Reserve Bank of St. Louis

143
in another district under arrangements w i t h the
Federal reserve b a n k o f that district a n d t h e
paying bank, i s worthy o f a trial a t least i n those
districts w h i c h f e e l t h a t t h e y c a n n o t c c r r e c t t h e i r

time schedules t o harmonize w i t h the actual time
now r e q u i r e d toe collect.

isting Regulation J

I t i s trve that under e x -

of the Federal Reserve Board

this practice i s not permitted, b u t inasmuch a s i t
is now being done effectively t o a very limited e x tent i n several o f the Federal reserve districts,
it i s believed that t h e practice could b e extended
within certain o f the districts a n d a t the option

ef the Federal reserve banks concerned with very good
results;

t h e Committee believes t h a t a

very material

reduction i n . float c a r r i e d b y t h e S y s t e m w o u l d b e
effected thereby.

"The Committee recommends that the Federal
reserve banks b e authorized a t their discretion,
conduct

to

a n e x p e r i m e n t a l o n g t h i s l i n e i n a n attempt

to arrange f o r t h e collection i n this manner o f checks
drawn o n the principal o r larger cities i n states
adjoining their districts.

S u c h a n experiment should


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Federal Reserve Bank of St. Louis

144

not b e undertaken without first ecbtaining a n opinion from Counsel f o r t h e Federal Reserve Board a s t a
the legality o f such a n arrangement, a n d , if. such
opinion is: favorable,
to modify Regulation J

i t would first b e necessary
to permit s u c h a procedure.

"The Committee regards a s highly dangerous a n y
attempt t o inaugurate radical changes without a
thorough a n d careful study o f the possible r e s u l t .
"Withdrawals f r o m

the p a r list.

" I n i
t
s report t o the November, 1924 Conference
of. Governors, t h e Committee recommended that t h e
following procedure b e adopted b y the Federal reserve
banks a n d branches in. order t o protect t h e sending
bank a s w e l l a s t h e r e c e i v i n g F e d e r a l r e s e r v e b a n k o r

branch against the possibility o f loss when checks
are recefived drawn o n banks which have b e e n removed
from the p a r list between issues o f the Federal
Reserve Board's semi-annual p a r list o r the monthly
supplements thereto:

"1. Any item under $50C,00 should b e charged
back a n d returned t o the direct sending member bank.


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Federal Reserve Bank of St. Louis

145
with a memorandum o r notation t o the effect that
the b a n k u p e n w h i c h t h e i t e m i s d r a w n h a s b e e n

removed f r o m the p a r list and, therefore, t h e i t e m
is net collectible through t h e Federal Reserve
System.

"2, A n y item o f $500.00 o r over should b e held

by the receiving Federal reserve bank c r branch, a n d
the direct sending member b a n k fram which t h e i t e m
was received should b e notified b y wire, t h a t t h e
bank upon which t h e item i s drawn has b e e n removed
from t h e par list a n d that t h e item i s not collectible through t h e Federal Reserve System, a n d should
be requested t o forward instructions a s t o the dispesition o f the item.

"The Committee has been asked b y one o f the
Federal reserve banks t o interpret o r amplify i t s
recommendation.

T h e request i s the result o f one

Federal reserve b a n k having concluded t o give t h e
forwarding member conte the choice o f t w o alternatives
only when wiring f o r instructions a s t o the dispo-

sition o f any item o f $500.00 a n d over; namely, that
the i t e m b e returned t o the sending member b a n k


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Federal Reserve Bank of St. Louis

146
or that i t b e turned cver t o one o f the commercial
banks
or that i t b e turned over t o ane o f the c o m m e r cial banks i n the city i n which t h e Federal reserve
bank o r branch i s located, a n d declining t o act
on instructions t o forward t h e item t o the drawee
bank t e b e accounted f o r direct t o the endorsing
bank from w h i c h t h e instructions w e r e received.

"The Committee t s of the opinion and therefore recommends t h a t a n y instructions t h e forward-

ing member bank may give, should b e complied with
by the receiving Federal reserve bank o r branch
providing t h e instructions a r e net incensistent w i t h
the law.

"Respectfully submitted,
"Standing Cammittee o n Collections
Strater, Chairman
Attebery
Walden, J r .
Coe

M.Toy."
Governor Norris. Now, Mr. Chairman, I
that i f a n y o n e h a s a n y q u e s t i o n

suggest

t o a s k that w e take u p

page l , e n d then g o t o page 2 , a n d s o on.
«

Time Schedule Showing Deferred Availability
Given by Federal Reserve Banks and Branches
for Checks Payable in States or Parts of States Wholly Outside of Their Respective Districts
Boston

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

147
The Chairman. G e n t l e m e n ,

a r e t h e r e e n y auestions

as t o page 1 ? I f not, w e will g o t o page @.
Governor licDougal. W h e r e i t speaks o f several banks
whose time schedules a r e accurate, I

think w e might give

consideration t o the schedules o f the other banks that a r e
not accurate.

Y o u h a v e e n u m e r a t e d t h e m i n t h e report,

My. Strater?
Mr. Strater. Yes.
The Chairman. Now, w i t h regard t o page 3 , which refers t o Boston a n d N e w York, a r e there a n y comments?
Governor Harding. Mr. Chairman, t h e banks i n the N e w
England district will object v e r y strenuously t o a n y

change i n cur time schedule. ;

had a careful an-

alysis made o f that, going back over 2 period o f years,
and we find that our average float, that is, the difference between t h e transit items a n d t h e deferred credit

items, amounts t c about $60,000,000 a day i n deferred

credit items; the average always is about $60,000,000,
put t h a t t h a t i s o f f s e t

o n the other side w i t h the ex-

ception o f o n e m i l l i o n d o l l a r s ,

a n d o n e millien dellars

is our averege float.
Mr. Strater.

Y o u ere speaking o f the aggregate d e -

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

ferred i t e m s

o n b o t h sides.

Governor Harding. Yes.
float w e a b s o r b t s a

I n other words, t h e average

million dollars.

I t i s not excess~

ive a n d does n o t mean a burden t o us. ‘ f o change this
will c r e a t e a

considerable a m o u n t

would involve extra expense, I

o f dissatisfaction,

have checked that u p and

it would cost u s more t h a n the interest o n the million
dollars.
Governor F a n c h e r .

Y o u spoke abeut cutting your fleat

down t o s a y a million dollars a

day o n the average.

Governor Harding. Yes, i t is about $60,000,000.
Governor Fancher.

O n one h a n d y o u receive t h a t f o r

two d a y s ' d e f e r r e d , w h e r e i t takes t h r e e d a y s t o collect,

and there i s constderable float, a n d i n the other schedule y o u d e f e r f o r a

longer p e r i o d t h a n i t requires

to

cellect t h e checks,

s o one offsets t h e other a n d reduces

the total.

Gevernor Harding. Yes. A

scientific adjustment o f

that thing I have estimated would cost us in the neighborhood o f $40,000. a year.
Goverr.or Fancher. Y o u mean 4 t would cost your bank
that?

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

249
Governor Harding. Yes.

Y o u gentlemen d o not under-

stand h o w hard i t i s t o change things u p i n the N e w England

states. They are set i n their ways, a n d i f you change anything i t raises a

racket.

Governor Fancher.

V e r y naturally, w h e r e a

bank c a n

get credit i n two days, w h e n i t takes three days t o collect, t h e y are going toa object t o a n y change.

Governor Harding. There i s a great deal o f offset
to it. You must admit that o n a n average volume o f
$60,000,000, y o u only have one million float, that i t is
not excessive.
Governor Fancher. There h a s always b e e n o n e feature
of this time schedule o f the Federal reserve banks about
which I have been a little fearful. T

a m afraid that

it will b e litigated some day and the time schedules will
be brought in.

T h e test o f a time schedule i s what

actual time i s required t e coliect items, a n d then when
it i s f o u n d t h a t w e d e c l a r e

a n item o n one point

i n two

days a n d collect i n three, o r defer i t s i x days a n d
collect i t i n four, I

a m a little fearful t h a t t h e

schedule i s not going t o stand up, unless i t pretty
nearly measures u p t e the actual time required i n collecting

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

the checks.
Governor Seay. Mr. Chairman,

a t this juncture,

it

will prebably b e o f interest t o the Conference t o have
me state that I

have just h a d a conversation w i t h Mr.James,

whe i s a member o f the Federal Reserve Board committee
which has special supervision over o u r district.

T h e oc-

casion f o r m y c o n f e r e n c e w i t h h i m w a s t h e n e a r b y o p e n i n g
of t h e C h a r l o t t e b r a n c h a n d t h e n e c e s s i t y f o r e s t a b l i s h -

ing a time schedule. I

thought probably t h e Board m i ght

desire t o b e consulted about t h e fixing o f the time
schedule, a n d I brought i t u p with Mr. James.
that h e has b e e n making a

H e said

study o f time schedules f o r

some months; t h a t h e has recently sent Mr. Snead around
te all t h e Federal reserve banks,
of their. fleat. I

t c make a n analysis

think h e h a s b e e n t o c u r bank.

H e

said h e d i d not speak for the Board, b u t h e believes t h a t
the B o a r d would,

a t a n e a r l y date, t a k e u p t h e q u e s t i o n

of the float i n the System a s a System matter.
The Chairman.

W h a t i s the tetal ameunt o f it? Dees

anybody know?

Gevernor Seay. A b e u t $70,000,000, h e said.

H e sug-

gested thet a s far a s w e were concerned h e would n o t b e


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Federal Reserve Bank of St. Louis

Lol
disposed t o take u p our case a n d made t h e suggestion
that w e analyze t h e float ourselves a n d that later, w h e n
the B o a r d t o o k up, a s h e b e l i e v e d

i t would,

t h e question

of the float i n the System, t h a t w e wruld have a hearing
befcre t h e Board.

The Chairman. Y o u r problem i s a very minor one,
Governor.
Governor S e a y . Very.

The Chsirman. B e c a u s e that n e w branch will handle
very f e w cnecks compared t o the number t o b e dealt w i t h
by all e f the twelve Federal reserve banks.
Governor Seay.

I t i s a very minor preblem a n d I did

net h a v e a n y i d e a t h a t i t w o u l d a f f e c t t h e S y s t e m g e n e r -

ally.

B u t the Board likes t o be consulted with regard te

the establishment o f these things, a n d I therefore took
the matter up, with t h e result I

have stated.

The Chairman.They have t o approve the time schedule.
Governor Seay. Yes. H e intimated that h e thought the
Board would net interpese any objection, b u t h e said he
had that stuuy before h i m end that t h e whole matter o f
the System fleat would come up.

H e believes,

a s Mr.

Fancher h a s said, thet w e were acting contrary t o the l a w


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in carrying a

gocd deal o f float i n the System, a n d

intimated t h a t i t w a s t h e opinion,

a t least o f many o f

the c o u n t r y banks, t h a t w e a r e c a r r y i n g a

very large pro-

portion o f that float f o r t h e benefit e f the c i t y banks.

The Chairman. I

am afraid that i s s o i n our dis-

triet. I s n ' t t h a t s o , M r . H a r r i s o n ? t h a t t h e c i t y b a n k s

get t h e benefit o f the float i n our district?
Mr. Harrison. T h e y all do, because t h e country
banks t h a t a r e sending t o u s get t h e benefit o f one
day's s a v i n g s

o n all points

Governor Talley.

i n t h e i r t w o - d a y schedules.

M r . Chairman, M r . Mills n a s s a i d

that h e would like t e come over within t h e next t e n o r
fifteen minutes.
Gevernor Harding. I

would like t o remark that a n y

extension c f c u r t i m e s c h e d u l e

o n certain points

i n

New York state, Pennsylvania a n d N e w Jersey, w o u l d result
in a very material increase i n the burden o n New York,
because a

great m a n y o f our banks would send directly t o

New York.
The Chaicman.

in some way.

W

o f course w e would hope t o change ours

e have a float now o f about $20,000,000,

ef which, accerding t e the calculations Mr. Harrison


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just gave me, t h e float within t h e district o r the intra-

district float i s @ix and a quarter million and the
inter-district float i s fourteen million.

T h i s arises

frem various reascns, w h i c h a r e described here a t length.

The intra-district float o f $12,800,000,

i n the week

when t h e analysis w a s made, arose i n items s e n t t o four
peints.

Geverncr Harding.

I f this thing ever comes u p before

the Board and I am asked to discuss i t with the Board,
fam geing t o call their attention t o the fact that
there i s a peculiar relationship between t h e N e w England
territory a n d New York; t h a t b u t f o r t h e desire o f
Coneress b a c k i n 1913 t o h e l d N e w Y o r k d o w n t o t h e l o w e s t
minimum p e s s i b l e a s t o size, t h e r e w o u l d n o t h a v e b e e n

any Boston district.

T h e r e wasn!t a

in N e w E n g l a n d f o r a

reserve b a n k there,

lot e f enthusiasm
and I

think

they would have been entirely satisfied t o have been a
part o f the N e w York district, a n d then this question
would never have arisen a t all.

The Chairman. Geographically i t is a sort o f uneconomical thing.
Governor Harding. T h e banking interests o f N e w


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England h a v e g n t t o k e e p c o n s t a n t l y

i n mind w h a t t h e y

are doing i n New York.
Mr. Harrison. B e f o r e t h e Federal Reserve A c t was
passed w e c o l l e c t e d t h e i t e m s

o n those points

i n t w o days

through t h e country collection denartment o f the clearing
house.

Physically,

t h e Federal] r e s e r v e b a n k s o f N e w York,

of Philadelphia o r o f Boston could col7ect t h e s e same
{tems

i n t w o days, w e r e i t n o t f o r t h i s a r b i t r a r y d i s -

trict line which was drawn, n e t s o much f o r collection
purpeses, b u t wholly regardless o f collection purpeses,
and solely f o r credit purposes.
The Chairman.

O r pelitical purposes.

My. Harrison. Y e s .

i

y en w e s u b s c r i b e w h o l l y t o t h e

no

principle that w e should/make payment for cheeks i n a
time s h o r t e r t h a n i t takes u s % n t h e a v e r a g e

t o collect

them, nevertheless w e d o feel that befcre w e change f r o m
the twe-day point t e the three-jay peint, t h e System
should consider first whether i t i s possible t o 2ell23t
a good vercentage o f those items b y direct sendings,

or

some other process, without a n amendment t o the law,
second,

i f w e cannet d o i t without amending t h e law,

whether o r not i n the interest o f expediting a

perfect


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collection s y s t e m w e s h e u l d n o t s e e k s o m e other, p e r -

haps drastic amendment~--not new, b u t later on--amendment t e the l a w which will permit o f a more scientifif
collection system.

I t i s a questiconc practical con-

venience a t the moment, whether w e should give u p
the
twe-day points under a l l t h e circumstances a n d subject
curselves t o very serious a n d bitter criticism e f all these
banks i n this whele area, o r whether w e should continue

tc hope that w e could eventually justify cur two-day
peint b y mcre speed} collections

i n some o n e c f the ways

that have been suggested a n d discussed.
Governor Fancher.

D i d your ccuntry clearing hcuse

in New York collect e n all this area that y o u are collecting o n now, o n two days! basis before?
Mr. H a r r i s o n .

O n two-day basis.

Gevernor Seay. T h e y got returns, but did they get
immediately available funds?

Mr. Harrison. Y e s . I t haprens that { n New York they
got returns o n New Yerk peints where t h e y h a d accounts
in New York.

Governor Seay. D i d they get them i n time for the
clearing house?


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Mr. Harrison.

A s a rule, I

The Chairman. I

understand t h e y did.

think the rules o f the country

collection division o f the clearing house reoguired New
York f u n d s

i n settlement

o f items s e n t t h r o u g h t h e

country clearing house.
Governer S e a y .

H a v e y o u e v e r m a d e a n y analysis

determine whether t h e y merély received a

to

return o r

whether t h e y received return i n funds available o n the
day o f receipt?
The Chairman.

T h e y got clearing house funds. There

wasn't a n y other kind then.
Governor Seay.

A s I

say, d i d t h e r e t u r n s c o m e i n

in time t e cleer o n the d a y o f receipt?
Mr. Harrison,

W e have estimated, f e r instance,

that i f w e could s e n d directly t c about twenty different
land

citfes i n New E n g / w
e could collect between 6 5 and 70
per cent o f the total dollar value c f all items o n
these points o n o r i n New England,

i n two days.

Governor Harding, A n y lengtheningcef our time schedule w o u l d c e r t a i n l y i n c r e a s e t h e b u r d e n
Governor F a n c h e r .

o n N e w York.

U n d e r thet method

c f collection

you have given t h e Boston banks a n advantage t h e y d i d


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not have under t h e N e w England e a r i n g House Assoclation, b e c a u s e t h a t w a s c o n f i n e d s i m p l y t e N e w E n g l a n d

cities.
Governor Harding.

W e did net give t h e m a n y advant-

ages that they cculd n o t g e t independent o f us.
Gevernor Fancher.

B u t t h e o l d system o f clearing

on

the two-day basis o n New England through t h e clearing
heuse association--

Governcr Harding. I wasn't there then and I do not
remember abcut that.
Gevernor Fancher.

I t did not g o outside o t N e w Ragland,

as I recall;
The C h a i r m a n .

M r . Harrison

and I

have discussed t h i s

at great length, and I think what we weuld like t o da,
agreeing, as we do, with the committee entirely i n principle, w e would like t a try t o work out a scheme t o get
mest o f thet stuff threugh i n two days.

W e might have

to get a little cooperation f r o m Governor Harding a n d
Geverner Norris.

J u s t h o w i t would b e done I

do not

know.

Governor Harding: I

think tae situation o f New York,

Philadelphia a n d Boston should b e considered separately


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Federal Reserve Bank of St. Louis

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from t h e s i t u a t i c n

i n t h e r e s t o f t h e country. I

to s a y o n e t h i n g further.

fron Boston t o New York.
past 5

or 6

o'clock

W

want

e have a i r mail service

I t leaves Boston about half

i n t h e afterncon.

A n y bank i n

Boston could collect a l l items payable o n New England
just a s quickly b y bunching t h e whole thing o n New
York
as they could b y sending i t t o the Federal Reserve B a n k
of Beston.

The Chairman. A n d get N e w Yerk funds i n two days.
Governor Harding. Yes.
The Chairman,

A n d t h a t w o u l d s u i t t h e m perfectly.

Gevernor Harding. Absolutely.
Mr. Harrisen.

I n changing t h e schédule f r o m twe t e

three days i t will simply b e a n admission b y the Federal R e s e r v e S y s t e m t h a t t h i s i m p r o v e d c o l l e c t i o n s y s t e m

that w e have given t e the country cannot d o for t h e banks
in t h a t a r e a w h a t t h e y h a v e a l w a y s b e e n a b l e t o d o f o r
themselves

i n t h e past, a n d w h a t t h e y w o u l d d e f o r t h e m -

selves i n the future, should w e institute t h e three-day
peint.

G n the other hand, I

think there igs n o denia]

ef t h e f a c t t h e t o u r p r e s e n t s c h e d u l e

equivalent t o giving a

o f t w o days i s

$14,000,000 surplus reserve t o


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Federal Reserve Bank of St. Louis

the m e m b e r b a n k s

i n t h o s e areas.

i

t I e m e r e l y « a dife

ference o f degree o f what w o contended f o r i n the. Pas-

cagoula ease, what w a contended should net b e done under
any circumstances,

a n d that i s o r

immediate sredit f o r

aid. item,
The Chairman. I
fleat. I

a m very anxious t e get r i d o f the

think t h e difficulty i n New England i s more

deeply rooted i n a way than i t i s i n N e w York. I

do rot

believe t h a t w e w o u l d h a v e t h e g r e a t d i f f i c u l t y t h a t w e

would have had a few years ago i n the New York Clearing
House.
Governor Harding. Y o u c a r see o u r difficulty.
The Chairman. I

appreciate y o u r difficulty perfectly,

GCvernor .
,
Mr. Harrison,

B u t incidentally

i t will n o t b e a

bed

of roses f o r us.
Tho Chairman, N o , i t will not. I

offer this suggest-

ion a s t o the three districts, beeause t h e y d e interlock
eloser t h a n a n y o f the others.

M y suggestion i s that

Mr. S t r a t e r m e e t w i t h t h e m e n i n c h a r g e o f o u r t h r e e

banks a n d work c u t some scheme o f cutting c u t this float
together,

e s a local problen.

W e must boa able t o iron


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Federal Reserve Bank of St. Louis

out a

great m a n y o f these difficulties, M r . Strater.
Governor Harding. I

think t h e three districts r e -

quire special study.
Mr. Harrison.

W e might have o n e collection agency

for these three districts,

t o which practically a l l t h e

member banks could send their {ftems, j u s t a s they d o
now under t h e present s e t up, a n d they could actually
collect t h e items probably i n two days.
Mr. Strater.

W i t h t h e excepticn

o f t h e banks o f

New York, B o s t o n a n d Philadelphia.
Mr. H a r r t s o n .

Mr. Strater. I

W i t h t h e e x c e p t i o n o f t h e i r h o m e C l b i,

cannet quite s e e Governor Harding's

point o f the Boston banksusing a i r mail a n d accomplishing t h e s a m e t h i n g a s i f t h e y d e p o s i t e d t h e i r c h e c k s

i n

the Boston reserve bank, bevause i f that plate leaves a t
6 o'clock a t night i t makes t h e m unavailable f o r u s e
until t h e following morning.

T h a t i s really neo quicker

than train service t e N e w York a n d therefore there i s
bound t o b e a less cof one day.
Harding correctly,

I f I understocd Governor

h e said t h e banks o f his district

comie, collect o n N e w England cities a s quickly b y sending


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Federal Reserve Bank of St. Louis

them t o New York.
Gevernor H a r d i n g .

New England cities.

No, I

said w i t h t h e e x c e p t i o n o f

Y o u did not criticise our time

schedule i n the N e w England states-~
Mr. Strater. N o , t h e committee h a s n e t eriticised
any a 8 @

matter

o f fact.

I

t i s j u s t t r y i n g t o discharge

its duty b y pointing o u t things a s t h e y are.
The Chairman. W h e n does that aernplane g e t back t o
Boston?
Governor Harding. I

do not know, b u t a geod many o f

the larger banks i n Boston have b e e n using i t t o a limited extent.
Governor Seay. Mr. James mentioned,

i n the course

of his conversation, t h a t o n e very small banker i n

Texas was complaing that the Texas reserve bank, o r the
reserve bank o f Dallas, d i d not carry for its member
banks t h e s a m e v o l u m e o f f l o a t t h a t c e r t a i n o t h e r r e serve b a n k s c a r r i e d

f o r t h e i r member banks.

Gevernor Talley. You cannot please everybody of
course. I

was just about t o s a y that, sco far a s the

Dallas bank i s concerned, w e wouid b e willing t o recognize this special condition which y e u have i n these


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three districts,

a n d subscribe

t o a n y n e w arrangement,

without a n y idea that w e ave sacrificing uniformity.
The distances i n our district a r e s c great, a n d aprlying
the r u i e t h a t t h e m e r e r e m o t e t h e p o i n t t h e l e s s t h e
volume,

o u r analysis s h o w s t h a t i t would b e cbjection-

able t o u s t e ungertake t a route direct i n t o other distriéts, b e c a u s e t h e m a t t e r i s o f s u c h s m a l l c o n s e a u e n c e

to us.

F o r that reason w e would b e very glad f o r the

three districts u p there,

o r even including t h e Richmond

district, o r any other district, t o work out a plan that
would overomme the difficulty. I

think Mr. Harriscn

said quite a n important thing when h e said that w e could

not suppert the principle o f a n tmproved collection
system, making comparison with foriel conditions a n d get
to the point where t h e present collection system i s

not a s efficient a s the other one, without these reserve
banks carrying a n encrmous amount o f float. I

even g o

so fer i n the analysis t o express t h e thevght that chose
three districts c o u l d clear these items, c h e c k against
each other i r the three districts, a n d settle t h e balances, because t h e y a r e a l l practically equi-distant
from t h e s a m e point.


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Mr, Herrison.

W e would b e satisfied t o have a n

amendment c f the law, o r a ruling,

o r agreement, t h a t

would p e r m i t u s t e s e n d d i r e c t l y t o a n y p o i n t

we have over-night train service.

t o which

A n arbitrary re-

striction through district lines prohibits u s from
doing that, a n d i t defeats t h e entire pessibility

of a perfect o r improved collection system. Y o u people
in the bigger districts out West have that solved
merely because your gecgraphical, limits a r e s o great.
You e a n send direct t e a n y point which i s within overnight t r a i n

s a e

e f you, b u t w e c a n n o t

d e f t merely

because o f this a r b i t r a r y barrier.

Geverncer Talley. N o t o n l y that, b u t c u r improvement enmes through constant improvement i n the mail
services, putting o n new trains, shortening schedules,
and all that sort o f thing.

Gevernor Bailey. S p e a k i r g o f available exchange,
I used t o s h i p a

carload

o f corn d o w n t o Alabama a n d

they would send m e a cashier's check, a n d charge f o r it,
and I would send i t back a n d they would s e n d m e a draft
on New Orleans a n d charge f o r it, a u d b y the time I
get m y money finally i t was t e n days.

T h e r e i s more


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Federal Reserve Bank of St. Louis

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difficulty i n getting i t just a s quickly a s w e
to under t h e o l d clearing house system, b u t w e
exchange better;
Governcr Talley. I

think Mr. S t r a t e r w i l l b e e r m e

o u n
t ithe statement that w e have shown a vast improvement i n cur timé schedules i n the last four c r five
years.

Mr. Strater. I

think so, .Geverner Talléy. I

think

it has b e e n constantly improving.
Governor Talley.

W h a t i s t h e difference

i n princi-

pis between t h e N e w York bank sending checks directly

inte the New England district-+
(At this point undersecretary Mills e f the Treas~
ury entered t h e Conference r e o m a n d t h e following proceedings w e r e had):~
The Chairman.

M r . Mills, a

q u e s t i o n c a m e up’ some

few minutes a g o which necessizated discussion w i t h the
Treasury D e p a r t m e n t 'd
n
a w e thought w e would tak: ad-vantagef t h a t a n d extend t o y e u o u r customary invita-

tion t o address the meeting o n any subject that you
have i n mind having t o d o with t a e Treasury Department
er r e s e r v e banks.


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The q u e s t i o n t h a t a r o s e w a s this. U n d e r t h e s t a t -

ute o f the United States, w h i c h date back t o the deys
of Alexander Hamilten,

n o final payment o f a n eobliga-

tion o f the United States i s made anywhere b u t a t the
Treasury Department i n Washington.

T h a t means t h a t t h e

coupons which w e pay, a n d all t h e Treasury checks a n d
Warrants a n d s o on, a r e charged t o the Treasury's a c @
count.

T h e y are stamped, b u t n o t cancelled, a n d are

sent t o Washington for examination.

T h e n the charge

which 1 s made t o the Treasury's accaunt becomes final.
In the case o f loss o r destruction o f a package o f these
vouchers, t h e question esrese a s t o whether thet charge
against t h e Treasury's account would become final, o r
what process would b e followed i n recovering f r o m the
Treasury i n t h e a b s e n c e

o f t h e vouchers.

We have had the subject u p t n New York and worked
eut a plan,

W e send t h e m cut b y express a n d insure

them f o r a theusand dollars.

T h e r e a r e copies made

of the accounts k e p t i n the bank, sco that everything

is identifiable b y symbol, a n d s o forth, a n d w e have
never had any trovble. T h e r e may be some question ine
volved. I

think a

bend i s t a k e n t o c e v e r p o s s i b l e


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Federal Reserve Bank of St. Louis

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loss, a n d w e p a y a

very s m a l l premium.

S o m e o f the

reserve b a n k s a r e i n doubt a s t o w h e t h e r e
w are proe

tected i n the event o f a train burning u p and a complete destruction o f all t h e evidence o f payment. I
suggested t a Governor Talley, w h o raised t h e questicn,,
that h e might t a k e i t u p with the proper cfficers
of the Treasury while h e i s here, ascertain their v i e w

about it, and make a repcrt.
Undersecretary Mills. I

think Mr. H a n d i s the best

man. The question has never arisen s o far as I know.
fhe Chairman.

W e had one case i n New York where

the cancelled papers c r mutilated papers o r whatever

it wasy amounting t o the neminal value o f a million
dollars, i n a mail. bag, was stolen.

T h e bag was slft

Open a n d dropped e u t o f the mail c a r alengside t h e
track. I

do not know h o w i t worked cut, b u t I

a m certain

that w e d i d n e t l o s e a n y m o n e y i n censegquence o f that.

Undersecretary tills.
to m y attenticn since I

T h e question h a s never come

have b e e n i n the department,

but I will reserve that t e look it up and get Mr.Hand
to talk i t o v e r w i t h Gevernor Telley before h e leaves,
if that i s satisfactory.


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Federal Reserve Bank of St. Louis

Oe

Governor Bailey. I

would like t o hear t h e report o n

that, b e c a u s e w e a r e t n t h e s a m e f i x t n Kansas C i t y .

Undersecretary Mills.

A l l right, I

will s e e that 4 t

goes t o all o f the Governors.
The Chairman.

M r . Mills,

a r e t h e r e a n y matters w i t h

relation t o the Treasury a n d the reserve banks t h a t y o u
would l i k e t o t a k e u p now?

Undersecretary Mills. I

do not k n o w o f anything.

The Cheirman. Anything i n connection w i t h t h e pending
financing?
Undersecretary. N o , I

de net k n o w o f anything that I

consider o f sufficient importance t o warrant m e i n taking
up y o u r time.

Governor Bailey. W h a t about the new currency?
Undersecretary Mills.

T h e n e w currency i s coming

along. They are meeting with any number o f mechanical
aifficulties, b u t they are gradually cvercoming them and
we hope t o begin issuing t h e n e w one dollar bills some-

time during the course cf the next fiscal year, I should
say about January 1 , 1929.

Governor Geery.

W i l l i t be pessible o r the desire

ef the Treasury t o redeem fit-for-use bills e f the o l d


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Federal Reserve Bank of St. Louis

168
promptly,

o r will t h e y b e wern o u t first?

Undersecretary Mills.

N o , w e will redeem them a s

as w e can, o n c e w e have a n adequate supply o n
of n e w ones.

The Chairman.

I n connection w i t h t h e plan o f

reducing t h e size o f the currency, I
American Bankers!

understecd t h e

Association passed a

resolution b a s e d

on the rettrement o f national b a n k notes.

I s that a

fact,Gevernor Talley?

Gevernor Talley. I

did not know about it.

The Chairman. T h e r e was a n account o f i t i n cne o f
the newspapers.
Undersecretary Mills. I
Governor T a l l e y . I

think I

s a w that.

usually a t t e n d t h e A . B . A .

sessions, l i k e everyone else,

i n the hetel lobbies, a n d

read the decisions afterwards.
The Chairman. I

think t h e question m a y come up. I

do not think i t is the general understanding that w e
are t o reduce t h e size o f national b a n k notes.
Undersecretary ijills.
Streng, I

T h a t i s e a question, G o v e r n o r

d o net t h i n k w e went t o raise a t this time,

as t o what w e are ultimately going t e de with the


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naticnal b a n k notes.

1950.

I t really will n o t b e a n issue until

W e are not i n position really t o retire t h e m

until 1930, and a premature discussion might very well
put t h e whele question i n t o pelitics. I

assume a

good

many c f the national banks will g e t very busy~-they a r e
getting b u s y now.

W e d o not want t e see a political

issue m a d e o f t h e question. I

think w e c a n g o a l o n g f o r

a considerable t i m e with t h e national b a n k notes o f the
present size, e v e n i f w e have a smaller currency. I

do

not think i t would tend t o increase their popularity,

but that 4 s something for time t o develop.
Treasury i s concerned I

S o fer a s the

think w e are prepared t o g o along

and work out our small currency program and leave the
national bank currency i n a class b y itself.
while w e c a n s e c w h e t h e r S h e r e t e a

I n the mean-

solution o f t h e m e -

chanical end of {t, and we will have an opportunity
to judge public sentiment o n the question o f retirement
in the course o f the next t w o a n d a half years.
Governor Harding.

D e y o u t h i n k t h e t i m e i s aprroach-

ing when i t wiil b e advisable t o put Section 1 8 o f the

Act into operation, b y offering these banks t o take
their b o n d s ?


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The Chairman.

i t i s approaching.

T h e twos have

gone up.
Governer Harding.

U f course that would o n l y take

care o f 2 5 million.
The Chairman.

A n d t h e threes h a v e also gone un, I

think.
Governor Harding. I

think i f meney ever gets t o the

point w h e r e y o u c a n p u t t h a t s e c t i o n b a c k i n t o e p e r a tion t h a t y o u w i l l g e t a

good m a n y v o l u n t a r y cffers.

Undersecretary Mills. Yes, but i t will b e a very
slow process t e work i t out a t 2 5 million a year.
The Chairman.

W e are limited t o twenty years,

and that will retire 5 0 0 million.
Governor Harding.

I t would o n l y retire about 1 5 0

million now.
The Chairman. T h a t i s all.
Governor Harding. B u t still i t would b e a step i n
the right direction,
Governor Norris. Mr. Secretary, a r e y o u personally
femiliar w i t h this reserve s t o c k o f n o w one dollar silver
certificates t h a t a r e being establihed a t the reserve
banks?


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Undersecretary wills. Yes.
Governor Norris. .
plaint

h a d a gocd deal o f com-

i n o u r o f f i c e c b o u t that.

T h e y understocd t h a t

it was t o b e really a reserve stock, b u t a s a matter o f
fact,

i n September t h e r e w e r e t w e n t y o n e withdrawals,

and i n the first twenty four days o f Ucteber there were
fifteen withdrawals, and, o w i n g t o the directions a s t e
how i t shall b e handled when n e w netes a r e received,

it

is necessary t c have a n assistant Federal reserve agent,
an a s s i s t a r t c a s h i e r ,

and

a n auditor,

a n d three extra

employees t o open the pouches a n d witness t h e receipt
cf the money.

I n addition e a c h package must b e inspected

in the case o f withdrawal i n the presence o f the same
number o f persong mentioned.
made daily,

a n d therefere

W i t h d r a w a l s a r e generally

a n certain d a y s t h a t shipments

are received, b o t h i n and c u t transactions a r e necessary.
Now, I
be p o s s i b l e

want t e ask the question whether i t would n o t
t e make t h a t a

real r e s e r v e s t o c k f r o m w h i c h

withdrawals w e r e o n l y t o b e m a d e i n c a s e e f a n emergency,
instead o f deity.
Undersecretary Mills.

T h a t w a s t h e c r i g i n a l fintene

tion, a n d that i s w h y I would l i k e t e lock inte it. Will


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172
yeu l e t m e h a v e y o u r memorandum, G o v e r n o r N e r r i s ?

Governor Norris. I
Governor Seay.
once.

will b e very glad to.

I n Richmond w e have t h e same experi-

I t i s practically a

Mr. Harrison.

continuous p e r f o r m a n c e .

I s n ' t i t due t o the fact, o r a t

least i s not this o n e o f the reasens f c r it, that t h e
soealled r e s e r v e s t o c k w a s r e a l l y e
t build u p t h e supply
in t h e t w e l v e r e s e r v e b a n k s o f u n i s s u e d n o t e s , w h i c h

would b e issued f r o m the reserve banks a n d not become a n

outstanding liability o f the Government until fissued b y
the reserve banks, a n d thereby saving float, w h i c h would
be quite considerable i n amount between t h e banks a n d
the T r e e s u r y ?

Undersecretary Mills. That was one feature o f it.

Mr. Harrisen. I

did net think you had gat to the

point where y o u had heped t e build u p a reserve s t o c k

in reserve banks. I theught that was the prime feature o f
it a t the time.
Undersecretary. Mills.. No, t h a t was o n l y one o f
the features. because i t was alse the. question c f space
which was invelved.
such s i t u a t i o n

W e h a d not certemplated a n y

a s Governor Norris

h a s described.


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Mr. Harrison.
York.

W e have t h e same difficulty i n New

I t requires t h e services o f two o f our officers

on a n average o f four hours a

day, each, t o handle it,

but that situation i s no doubt due t e the fact that the
Treasury, i n issuing currency, hes got t o issue the
lowest number first, t h e lewest seria] number, a n d t h e
result i s that i f y e u d e have a

steck there o f a n y kind

there i s beund t e b e a turnover i n i t owing t o that difficulty i n having t o issue t h e lewest serial number first.
Undersecretary i l l s . T h a t m a y b e the answer t e it.
The Chairman.

I s there a n y further d i s c u s s i o n o f this

currency m a t t e r ?

Governor Bailey. I would like t e know what our cbligation i s t o t h e T r e a s u r y w h e n w e h a v e p a i d t h e s e v o u c h -

ers, stamped them paid, a n d put them i n the express
office a n d sent t h e m back. T h a t i s where o u r connection
with t h e thing stops.
Undersecretary Mills.

T h a t w a s t h e question Governor

Talley raised, w a s i t not?
Governor Talley. Yes.
Governor Norris.
cashed t h e m .

Y o u h a v e n e t p a i d them;

y o u have


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The Chairman. Gentlemen,

i f there i s n o further

discussion e f this matter, t h e r e f s c n e topic o n the

program that I am geing t o ask tir. Harrisen t e pring
up while Mr.Mills i s here. T h a t 4 s III, sub-topic B ,
Treasury practice i n making purchases o f geld a t mints
and assay offices.

T h a t i s especially Mr. Harrisen's

topic.

III. C o i n , Currency a n d Circulation.
B. T r e a s u r y practice i n making purchases
of gold a t Mints a n d Assay Offices.
Mr. Harrison. F o r a period c f two o r three years,
perhaps longer,

w e have been discussing tnformally with

officials o f the Treasury t h e practice o f the Treasury
‘comparison w i t h other
Department i n making purchases c f gold i n / g o l d centers,
such a s London, Berlin, Amsterdam, a n d soa forth.

A s

we all know, t h e Treasury has,in buying gold, p a i d mint

parity for the gold and made a n immediate advance o f 98
per cent o f thot mint parity when the gold i s deposited,
paying t h e final 2

per cent w h e n t h e final report o f

assay i s received. T h e result c f the difference i n practice
at these centers h a s b e e n that t h e United States
pays more f c r gold than a n y other
the world.

g

o

l

d market i n

T h i s practice w a s first started a w a y back i n


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1878, w h e n there was perhaps a

real reason f o r t h e

Treasury making t h e immediate advance, a n d that was t o
enceurage deposits o f gold a t the Treasury a n d not t o
discourage it.

T h e Secretary w a s given authority,

under the law,--while net a mandatory one--he was given
permissive autherfity under t h e l e w t o make advances o f

98 per cent for the full face value ef the gold tmmediately upon receipt o f the depasit.

New, a s you all know, w e have i n the United States
over h a l f o f t h e w o r l d ' s m o n e t a r y s u p p l y o f gold.

the moment w e are n o t desirous, certainly,

A t

c f creating

any artificial encecuragement o f the flew o f gold i n
this way, a n d i t has occurred t c us, therefore, t h a t

there might b e seme advantage, naticnally and internationally,

i f w e could edapt c u r practice somewhat

to

the practice o f other markets c f the world, a n d not
make immediate advances, b u t ewait final assay.

soa

that t h e result would b e equivalent t e making a

dis-

count }

rom

t h e full face value o f the gold purchased b y

the Treasury.
In Lendon,

a s y o u perheps e 1 1 know,

t h e discount

that t h e Bank c f England pays i s equivalent t o one e i g h t


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per cent c f the mint parity.

T h a t discount, w h i c h they

make i n their buying price, w a s designed t o cover t h e
less o f interest t h a t would b e suffered b y a depositor

if heshould take his gold t e the Reyal Mint, wait for
the gold t o b e minted, a n d get his money b a c k i n geld.
The same practice prevails i n other markets, a n d I

have the figures.

I n The Netherlands, t h e ciscount, in-

stead e f being . 1 6 , 1 8 . 3 5 per cents i n Switzerland
it is. . 4 3 ; d n Bertin, 1t¢ is . @ 1 , a n d i n the United
States t h e d i s c o u n t

i s ..013,

o r a p p r o x i m a t e l y o n e ‘tenth

ef what i t i s i n Londen, which i s the largest o f our
gold markets.
Now, under t h e law, w e feel that i t i s competent
for t h e Treasury t o issue a
defer t h e t r a d v a n c e s f o r a

regulatien whereby t h e y will
period o f f i v e t o t e n days,

or perhaps m a k e n e advance a t all o n acceunt o f gold
deposited,

a n d make final payrent w h e n t h e final a s s a y

is néceived.oniy.

T h e r e a r e a number e f disadvant:ges

te that, peliticel a n d etherwise, b u t that i s the thought
in the minds o f all o f u s whe have censidered it.

W e

have estimated that the demestic production ef gold i n
this country i s appreximetely $50,000,000 annually.


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All o f those domestic producers o f geld would ratse a

howl immediately 1 f there was a regulation o r law equivalent t o a discount e f . 1 6 per cent, o r a n y other
discount o n the gold that t h e y produced.

T h e question

came up, then, whether i t might n e t b e possible t o

give up the practice o f making immediate advances o n
enly the coin or imported menetary gold, and whether i f
that were done there would b e a n y legitimate complaint

by anybody. T h e only enes that could preperly complain

would perhaps b e the importers o f gold te this country,
but they are merely acting a s a g e n t s e
t bring the gold
in because o f the fact that i t i s profitable t o them t o

do s o at a certain given peintin the exchange rates.

If we changed that practice the result might merely be
that w e would lower the gold export peints fer those

various fereign markets. I
and I

think t h e e t h e r s

do not believe myself,

o f u s f e e l t h e s a m e way, t h a t

there would b e eny real crmplaint e n the part o f the
fereigners generally,

i f w e should change o u r practice,

because s u c h things a s w e hear n e w about o u r gold

policy are that w e are hoarding the gold o f the world
rather t h e n t h e fact that w e are repelling it, s o that


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178
a change c f p r a c t i c e
than g i v e f u e l ,

a t this t i m e might answer, r a t h e r

t e some o f t h e discussicns t h a t w e hear

abroad about o u r gold practice.
Governor Seay.

I s there a similar practice i n

Canada, M r . H a r r i s o n ?

Mr. Harrison. I

d o net know what t h e practice i n

Canada amounts toe, Geverner Seay.

W e might well l o c k

inte that.
To p u t i t a

little d i f f e r e n t l y , s t e r l i n g e x c h a n g e

has g o t t o g a down only a point a n d a half before i t

reaches the gold export point from Lendon,
The Chairman.

B e l o w mint-pearity, y o u mean?

Mr. Harrisen.

B e l o w mint-parity, y e s .

R e f c r e we

lese gold t o Lendon sterling exchange has get t o g o up
twice that amount,

o r pretty nearly three cents, a n d

while s e m e c f t h a t d i s p a r i t y i s d u e t o d i f f e r e n c e

i n

freight rates between eastern a n d western shipments,
most o f i t i s due t e the fact that w e have this practtee o f m a k i n g i m m e d i a t e a d v a n c e s

o n account

o f geld

peught.
The Chairman. T h e r e i s e n e paint also, a n d that
43 t h a t i f t h e T r e a s u r y s h e u l d d e c i d e

t o abandon t h e


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practice o f making c a s h advance o f 9 8 per cent, guarr
anteed value c f the gold, t h e Federal reserve banks
would t h e n b e i n a position t o step i n and t o make a
bank price f o r cash, p a y cash f o r that gold, w h i c h

would send all the gold t o the reserve banks, because
they weuld b e the cash market.

I t happens i n all the

ether markets t h e t t h e gold gees t o the cash custcmer,
the bank c f issue, a n d that i s now t h e statutory practice
in England.
Mr. Harrisen, A

survey o f the different mints

and a s s a y offices s h o w s t h a t i n N e w Y e r k t h e f i n a l a s s a y

is ysually received abeut t e n days after t h e deposit.
That i s a much len,er peried t h a n i s the case j n any
other mint o r assay office, a n d t h e practical effect o f
this i s that t h e discount which a depositor would have

to suffer would b e greater i n New York than anywhere
else. C o n v e r s e l y ,

t h e contro!

w h i c h t h e reserve b a n k

would have over the monetary price o f gold would b e

greater i n New Yerk, because the discount i s greater.
We d i d n o t f i n d t h a t t h i s d i f f e r e n c e

i n the vractice

different m i n t s w o u l d h a v e a n y m a t e r i a l e f f e c t u p o n

what w e are desiring t e accomplish, because i f the

at


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practice i s limited t o the menetary g e l d i t will b e
practically iimited t e New York,
such a

big percentage

i n any event, because

o f the imported g c l d comes i n t o

New York,
The Chairman. T h e Treasury,
some interest b y this, b u t I
amount te.

e f course, w o u l d save

do net k n e w what i t would

I f this practice h a d been established scme

years a g o with t h e geld that w a s coming in, i t would have
saved a great d e a l o f interest.

T h e r e was 2

lot o f

money invested i n geld that w a s n o t available tec the
general fund.
Mr.Harrison.

I n effect,

i n t h e past, a l l g e l d c o m i n g

inte t h e ceuntry hes b e e n put into t h e melting p o t because there was n e real market f e r i t cther t h a n t h e
assay effices a n d t h e mint.

T h a t was done neo matter what

kind o f gold i t wes, e v e n i f i t was perfectly satisfactory g o l d b a r s o f t h e b e s t a s s a y e r s a b r o a d .

T h e goid

would b e destroyed, remelted i n Up,ited States mints.
Just t o show you how sensitive the market is, twe years
ago,

when

w e went i n t o t h e market

f o r foreign bars,

possibly a l l o f t h e b a r s t h a t c a m e t e N e w Y o r k w e r e s o l d

to u s rather t h a n t o the assey office, because t h e


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final t w o per cent payment, w h i c h was deferred t e n days
in t h e a s s a y office, w a s d e f e r r e d o n l y t w e d a y s i n t h e

reserve bank, pending t h e weighing o f the bars that were
bought.

T h e differénce b e t w e e n t h e t w e days a n d t e n

days i n the final twe per cent has breught u s the gold
rather than bringing i t t o the assayers.

T h a t plus the

fact a l s e t h a t t h e member banks w e r e v e r y d a n tn cai o f

cooperating with us fn any event.
The Chairman.

I n commenting o n this proposal t h e

twe things that stand cut i n my mind sbout i t are, first,
the matter Mr.Harrison mentioned a s t o domestic protection.
There has b e e n s o much discussion e f the plight o f these

people that i t would hardly b e advisable t o adopt a regulation which would penalize them i n the price they get
for thetr gold.

T h e second i s i t means a

reduction i n

the price that w e pay fer gold i n this country o f maybe
one-eighth o f one per cent. That i s the way i t figures
eut roughly.

Mr. Harrison. Yes. I t would be .16, or about oneeighth of one per cent.
The Cheirman.

I t would naturally create comment

abroad that w e were doing something that was quite


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unusual. S o m e of the nations have deliberately reduced t h e price e f gold b y 5 per cent.

N o w Switzer-

land has p u t a n embargo o n the impertation o f geld, a n d
we are taking it.
Mr. Harrison.

T h e r e i s another important considera-

tion, a n d t h a t i s this, t h a t i f w e p u t a

handicap

on

gold bars, o r make t h e m less valuable i n the geld market,
net

there is geing te be a tendency/tc withdraw the bars ‘for
export a n d expert U . S . geld coin, a n d that i s going t o
be a

more e x p e n s i v e p r e c e s s t h a n m a k i n g bars.

T h e Bank

ef England h a s been able t o centrol that largely because

they would pay out light weight coin. W h e n I say"light

weight” I mean within the limit of telerance, but abraded
CON.

W

e could follow t h e game practice w e r e i t not

fer the fact that w e haven't a n y e l d c i r c u l a t @
® coin.
Mest o f t h e c e i n t h a t w e h a v e g o t n o w i s n e w coin.
proposition h a s b e e n p r e s e n t e d

T h e

t e u s very concretely

in

an order f r o m Brazil f o r a n expert c f some thirty s i x
millions i n cein, a n d w e have o n l y twenty millien i n

circulat®@ c o i n that w e can pay out and w e have get t o
pey cut t h e balance i n new coin, whether w e want t o
Air W A G .


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183
The Chairman. T h e circulated c c i n that w e have
had experience shows a n abrasion value o f abcut cne-

fourth o f one per cent and some three-eights. T h a t i s
abeut d o u b l e t h e m i n t r e d u c t i o n

i n the price c f gold a n d

that would overcome t h e disadvantage a n d stimulate t h e

taking o f bars rather than the gold coin.

B u t we

haven't g o t t h e a b r a d e d c o i n t o p a y out.

Gevernor Seay. Y e u furnish t h e circulated, coin a t
face value?

The Chairman. Oh, yes, a s leng a s i t is within onehalf c f ene per cent, w h i c h i s the limit o f tolerance.

Mr. Harrison. T h e Bank of England used to grade
their c i r c u l a t i e d n
i
o
c inte varieus groups within che
limit c f tolerance, depending u p e n whether t h e y wanted

to lose o r keep gold, a n d depending upen that, they
would p a y c u t l i g h t g o l d o r h e a v y g e l d accerdingly.

The Chairman.
there.

T h e y understand t h e prepdsition

T h e y h a d tons o f abraded c o i n o v e r i n those

countries where t h e y have t h e m i n circulation, s u c h a s

Germany. I imagine they have all got ample supplies.
Hereafter,

w h e n t h e y s e n d t h e sbraded e o s n o v e r here,

will k e e p i t a n d s e n d i t b a c k t e trem.

we


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Federal Reserve Bank of St. Louis

184
ip. Harrison.

E v e n with i t s disadvantages, t h e r e

13 s o much t a b e said f e r this program,

i f i t i s feasible,

that w e are mest hepeful t h e t i t will b e peussinle

f o r

the Treasury t o work cut, perhaps n e t this precise ProO=
grem, b u t some program that will have seme n e t effect c f
reducing t h e price that w e are n e w paying f o r geld i n
competition w i t h all the rest o f the world. I
instance, t h a t a

know, f o r

goed part o f the gold that w e got early

last spring a n d late last winter f r o m France, w o u l d n o t
have come t c this country were i t net f e r t h e fact that
we paid more than a n y cther market, a n d there was a
shipment c f practically 130,900,000. involved,
The Chairman,

A s Mr. Herrison says, t h i s matter h a s

ween d i s c u s s e d f o r a

l o n g time, a n d t h e f e e l i n g h a s b e e n

thet t h e r e w e r e sec m a n y e l e m e n t s i n v e l v e d

i n tis that i t

might b e unwise f o r t h e Treasury t e issue a

new regula+

tien out o f a clear sky, a n d s o w e have preposed t h e
prepapingcf a

very careful article, describing t h e whele

problem hypcthetically, h a v e i t published semewhere
where i t weuld heve wide circulstion, a n d s e e what t h e
publie r e a c t i c n w a s h e r e a n d abroad,

M r . Willis h a s

suggested that t h e article sheulc appear i n the Bulletin.


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That struck m e a t the time a s a gard plan.
reflection, however,

O n further

w e are l e d t o belteve t n New York

that t h a t w o u l d m a k e f t a p p e a r a s t h e u g h t t w a s r e a l l y

@ propesal o f the Gevernment b e i n g p u t c u t b y the Fed4

eral reserve board, a n d w e believe w e should secure t h e
publication o f i t i n some magazine o r publication with
very wide biseudatien ameng people w h o study these things
and p r e b a b l y g e t a
to i t a t all.

better r e a c t i o n , w i t h e u t a n y k i c k b a c k

T h a t w a s t h e l a s t w o r d i n N e w York,

as I

remember it.
Mr. Herrisen, I

have f e l t t h a t w a y m y s e l f v e r y

strongly a n d I think the others f e e l that.

The Chairman. D r . Burgess feels that way. H e w d o
you feel about i t now, Mr. Mills?
Undersecretary Mills. I

have n e t felt that i t weuld

be quite a s much cemmented o n i n this ccuntrysThe Chairman.

I t will b e abread, a

great deal, a n d

it might b e eenstrued a s a possible difference between
the T r e s s u r y a n d t h e r e s e r v e S v s t e m ,
fully y e u w o r d t h e article.

n o m a t t e r h o w care-

I t will b e very difficult

get a c r e s s w h a t w e h a v e i n m i d g e t t i n g a c r e s s w i t h o u t
giving t h e i m p r e s s i o n t h a t w e a r e p t o u t s w i t h t h e

te


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Treasury.
Undersecretary Mills.

T h e Treasury Department its

whelly symoathetic w i t h the idea, b u t w e did feel that
inasmuch a s t h e m a t t e r d i d n o t p r i m a r i l y c o n c e r n t h e
Treasury,

b u t rather c l e a r l y c a m e w i t h i n t h e jurisdict-

ien c f the Federal Reserve System, t h a t i t would b e better
if the suggestion emanated f r o m the Beard i n the form
of a suggestion, s i m p l y f e r discussion, a n d then s e e what
the public reaction weuld be. I

de not think i t i s a

matter o f great consequence whether i t appears i n the
Bulletin o r i n some cther publication that will fnsure
public discussion.
fault i n it.

W

e have n e t been able t o see a n y

I t looks t e u s a s a whelly sound proposi-

tion.
The Chairman. T h e r e has b e e n seme complaint abroad
that t h e r e i s n e gquetation f e r g o l d i n t h e U n i t e d S t a t e s
in t h e f o r e i g n markets.

W h a t i s meant

y y that i s t h e

fact that t h e whele werld lecks e t the Lenden market
where gnid i s seld publicly.

E v e r y Henday c r Tuesday

all geld which gees t o Lenden i s seld a t what i s equivalent t e a n auction a t t h e Rethchilds! C o m p a n y offices.
There t h e bidders f o r geld make cffers o f the bank's


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statutory price, w h i c a i s 8 4 Shillings 1 0 pence, f o r a
fine ounce, p l u s a n y premium that t h e y are willing t o

pay.

T h e gold which is. not sold ta be taken to India,

Germany, o r wherever i t 1s wanted, o r taken b y the manufacturer t o manufacture i n a n industrial art, goes auto-

matically te the Bank of England at its statutory price
of 84 shillings and 1 0 pence. W h e n the bank takes the
gold t e t h e mint, t h e c o i n t u r n e d b a c k i n sovereigns

te the bank a t the rate o f 8 4 shillings a n d 1 1 ha'pennies

in gold coin, a difference o f cone and a half points, which
is the equivalent o f the interest yest during the time
that t h e c o i n i s m a n u f a c t u r e d ,

and a

difference

c f that

same character, pessibly i n exactly t h e same ameunt,

which this plan would produce i n our practice, would result, a n d then i f a n y buyer e f gold wanted t o buy geld
We might i n the course e f time develop a

practice i n our

market semewhat similar t o what preveils ebroad.
Mr. Harrisen.

I n that connection I

think i t i s

worth mentioning, teo, that i t hes been @ great help
in the situation t o have the Treasury remove the bar
charge e n the gold seld b y the Treasury.

W e never h a d

eny basis eon which t e t r y t e persuade t h e foreign buyers


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of our gold t o take bars instead o f coin when w e h a a
an extra charge o n the bars; a n d while w e are n o t making
very much progress now, w e ere making some progress i n
getting t h e m t o take bars rather t h a n coin, a n d w e hope
to make a

great deal mere progress a s time gees along.

The Chairman.

I n that cennecticn, what i s the stetus

ef the supply c f geld cein, Mr. Harrisen?
Mr. Herrisen.
eoncerned

I t i s very bad, s e far a s w e are

i n N e w York;

i t i s weak.

L o o k i n g at it

nationally, t h e situaticn i s very much better t h a n i t
was t w o yeers age. T h e Treasury h a s minted, I

sheuld i m -

agine, i n that time aporoximately $200,000,000 i n gold
coin, a n d while most cfthoeir coin i s n o w used a s t h e

base for certificate issues, nevertheless the coin is
here and is available i f we have te have i t qn an emergency, either b y some method of reducing the ecin base
ageinst the certificates o r a pelicy of retiring certificates i n order t o release t h e gold coin. T h e ameunt o f
excess c e i n i n t h e country, o v e r a n d a b o v e t h e b a s e f o r

certificates,

f s not nearly a s large a s w e would like t o

see it, a n d i n the N e w Yerk bank, while w e were able t o

build eur supply o f colin up t e about $80,000,000 a


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shert while age, nevertheless withdrawals c f $31,000,000

for the Argentine and new $36,000,000 for Brazil, has
made c u r pesition very much weaker again, a n d I

do not

believe that there will b e mere t h a n about thirty-five
or ferty millions i n coin left i n New Yerk, including
what i s i n the assay office a n d the Federal reserve
benk, after this shipment i s made t o Brazil.
I have j u s t r e c e i v e d a

cable, w h i c h w a s j u s t h a n d e d

to me, that w e would b e called upon next w e e k for fifteen
millien f e r Poland. I

here ‘and expect that Peland will

take bars. O f course they have the right t c take coin,
but with these immense balances t h a t w e heve o f the

banks e f issue i n New York, seme o f which banks may want
ecin and expect u s t e ship coin, o u r position i s not a

bit tee streng and i n my epinicn i t is quite dangerously
weak,
The Chairman.

W e have these obligations sgainst

us, a n d anyone abroad c a n demand coin, a n d legally de-

mand it.
suppese, a

I f these fereign banks o f issue which have, I
billion dollars e f demands u p e n u s sheuld

suddenly decide that t h e y want t o take their geld, o r
any considerable p a r t o f it, t h e y heve a perfect right


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ta p r e s e n t t h e i r d e m a n d t o t h e F e d e r a l r e s e r v e b a n k

and a s k fer coin, a n d t h e coin dre3 n e t exist t o meet
that demand.
Governor Fancher.

M a y I gnquire i n what f o r m y e u

ear-mark this gold?
Mr. Harrison, T h e r e i s a small part c f gold that
we have ear-marked i n ccin, b u t t h e great b u l k o f i t i s
fin bars.

A l l t h e eeremarks

w e a r e making a t t h e pres-

ent time a r e i n bars.
The Chairman. I

de not think t h e situation would

be quite a s bad a s i t appears f r o m t h e figures, because
the mint c a n turn e u t about fifty milliens a

month, a n d

there i s a limit t o the shipping facilities employed i n
carrying t h e gold, t e any one peint, certainly.
we c o u l d k e e p u p w i t h t h e demand,

While

i t might b e v e r y i n -

cenvenient a n d pessibly embarrassing.
Mr. Harrison.

I n this connection I

think i t would

be interesting t o censider, f r o m the System print c f
view, t h e status o f our gold reserve,

W e have approxi+

mately three billion dollers i n reserve. W e speak o f a
System reserve ratio o f around 7 5 t c 8 0 per cent.
a matter

o f actual f a c t t h e p e r c e n t i g e

A s

e f payable g o l d


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reserve i s very, v e r y small, a n d o n the last figures
we have i t i s about 2 0 per cence, speaking roughly.
Governor Bailey.

T h e rest e f i t i s i n bars?

Mr. Harrison. T h e rest o f i t i s i n bars, a n d i n

ten thousand dellar gold certificates, which w e d o net
consider i n the class o f payable g o l d reserve. I
give t h e figures f o r i n d i v i d u a l b a n k s , b u t thet
worth while.

T h e a v e r a g e f o r t h e System,

i s not

t h e percentage

of payable g o l d reserve f o r t h e whele System,
last figures, w a s 19.5 p e r cent.

can

o n the

T h e compesiticn o f the

gold reserve f o r t h e System a s a whole i s this: 6 5 per

cent i s i n the gold fund, 8 per cent i s i n Frllien i n
vaults o f the reserve banks, &

per cent i s i n coin, a n d

19 per cent i s i n geld certificates.

T h e vercentage

in the gold fund t s net a s great a s i t was two years
age, I

think t h e r e h a s b e e n a

considerable i m p r e v e m e n t

in converting from the gold fund t o the vaults o f the
banks i n the past eighteen menths.

W

e ourselves have

at different times taken appreximately 150 t o 200 million
of gold bars from the ssay office and taken them t o

our vaults, and reduced eur geld fund acecrdingly.
While w e d e n a t f e e l t h a t t h e s a m e r e c e s s i t y e x i s t s


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fer t h e o t h e r r e s e r v e b a n k s

reserve i n t o vault reserves,

t e convert t h e i r g o l d f u n d

i t i s true nevertheless

that s o m e o f t h e m a r e v e r y l o w i n vault r e s e r v e a n d

might, j u s t a s a matter o f recerd, consider building
up their bullion c f coin reserve.

A s a matter o f fact,

the weak peint o f attack a t the moment i s the N e w York
bank a s far a s gold c o i n reserve i s concerned.
Geverner Wellbern. I

should think that t h e foreign

governments w o u l d p r e f e r b a r s t e ccin.

The Chairman. Unfortunately t h e y d o nat, because
they enticipate t h e pessibility e f having toe shift i t
back here.
Governor Fancher.

O u r Beard started ebout t w e years

ago t o increase our supply c f coin u p t e #25,00C,000,
but w e haven't b e e n a b l e t o g e t a n y c f it, s o t e speak.

‘The Chaizman.. A n c t h e r unfertunate situetion abeut
the geld settlement fund, especially, 48s the very high
percentage o f cur reserve i n that fund, w h i c h reduces
the properticn c f geld available f o r expert i n case a
heavy demand arcse, because while i t i s a part o f the
reserve w e ceculd net take i t out a s leng a s w e maintain
so m u c h o f i t i n t h e s e t t l e m e n t fur.d.

A

t times w e have


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debated i n New Yerk whether i t might n o t later b e desir-

able t o have n e geld settlemens fuiad at all, but have
settlements between t h e Federal reserve banks effected
by b e c k entries, w h i c h c o u l d v e r y r e a d i l y b e dene, a n d

some regular methed devised f o r dressing t h e reserve
conditien b y shipments

o f gcld that ultimately became

necessary between t h e reserve banks, c u r shipments
ef certificates, w h i c h e f course would b e much better.
Mr. Harrison. S i n c e s l l e f the reserve banks have
their n e w buildings a n d t h e mest impreved f o r m c f vaults,
from the viewpeint c f naticnal interest w e have censidered the question c f whether i t i s necessary t c have

over three billicn dollars e f geld i n ene place, a s is
now t h e case,

W h i l e w e have n o ceubt a t all that

these vaults i n which the three billicn is new put
are the best and mest adequate kind c f vaults, nevertheless, i f it is feasible, i t might b e a wise thing t e distribute seme e f thet metallic gold ameng cther vaults,

which are at least equal ter, if net better, than the
enes i n w h i c h i t i s n o w located.

A few moments a g o I mentioned,

i n discussing t h e

pregress that has been made b y the Treasury i n building


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up their steck o f gold coin reserve, w h i c h they have
dene quite considerably i n the last year, t h a t there
has b e e n a large imprevement e v e r what t h e situaticn
was a t that time,
just received,

I n reviewing t h e statement I

have

o f November 1 , f r o m the Treasury, I

that t h e i m p r o v e m e n t

i s e v e n m u c h better t h a n I

indicated i n talking t e the Conference a

find

had

few moments

ago, a n d i n d e e d b e t t e r t h a n I

myself t h e u g h t

i t was

when I was discussing it. :

£ e c e r d i n g t e the cal-

culations here, t h e ameunt c f gold certificates cout-

standing i s $1,613,000.

T h e tetal amount c f gold coin

in the Treasury i s $692,900,000, which weuld make a n
excess o v e r t h e base required f e r certificates o f

$160,000,000. W h i l e , therefore, I pictured a very
gloomy situatien i n New York, i t - i s chiefly geographical,and
eculd b e quickly remedied b y shipments f r e m t h e mint
at PRhitadelvnia, w h e r e t h e b e t t e r p a r t e f t h i s g o l d

new .exists.

O n e o f the influences t h a t perhaps h a s

contributed t o m y f r a m e o f m i n d a b o u t i t h a s b e e n t h e

fact that t h e Treasury has h a d serious difficulty i n
getting s u f f i c i e n t a p p r o p r i a t i o n s
about,

t e move t h e g e l d

and in t r y i n g o
t suppert t h e c e n t e n t i o n t h a t


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it i s a Treasury expense rather t h a n a reserve b a n k
expense w e h a v e c e n s i d e r e d
perable e b s t a c l e

t e getting

i t a t t i n e s a n almost i n s u 6.

B u t bhetaute p u r e l y a n

internal preposition between u s and the Treasury.
between t h e U n i t e d S t a t e s a n d f o r e i g n b u y e r s

A s

o f geld

coin, semehew, s o m e way, e v e n i f w e have t o p a y the
ex-

penses ofrselves i n getting the coin, elther i n PhilaCelphia o r N e w York the cein i s abetlable new, t e the
amount c f $160,000,090 excess.
The Chairmen.

I s there anything further w e wish t o

take u p before Unde: secretary Mills?

I

f net, w e are

very much cbliged t e you, Mr. Ilills.
Undersecretary iiills. Thank y e u very much, gentlemen. Governor Talley,
venience

i f you will come i n a t yrur con-

w e w i l l s e e w h a t w e c a n f i n d cut. I

a m taking

Governor Nerris! memorandum with me.
(Undersecretary Mills thereupon left the Cenference
room, and the preceedings continued a s fellews):
The Chairman. N o w , Mr. Strater, w e are back t o
your repert, a n d w e were discussing this question c f
combining t h e t h r e e d i s t r i c t s

Philadelphia.

c f Boston,

N e w York a n d


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Geverner Talley. M r . Chairmen, I

was i n the midst

of a n o b s e r v a t i o n w h e n M r .Mglls c a m e i n . I
any d i f f e r e n c e

cannot s e e

i n principle b e t w e e n t h e F e d e r a l r e s e r v e

bank sending direct t e a member bank f n another district
and a member b a n k i n another district sending direct t o
another Federal reserve bank. I

de net s e e where y o u

have t e have a n y amendment t o the a c t t e permit sending
between districts a s y e u might desire.
Mr. Harrison

W

e have always assumed that w e have

had legal autherity t o send t o the bank i n opPringTield,
for instance, providcec t h e Federal Reserve B a n k o f Boston
would authorize u s t e use a devble erdorsement stamp. I
knew there a r e certain objections,
double e n d o r s e m e n t s t a m p ,

i n principle,

t o this

b u t t h e y a r e i n u s e already,

and I understand s o m e o f the reserve banks authorize
their o w n member banks t c use t h e endorsement stamp, a n d

have i n the past authorized them t e use the double endersement, including t h e Federal reserve b a n k endorsement.

I f , f o r instance,

w e have authority; from the

Federal Reserve Bank o f Boston a s their agent, i f you
will, t o send items direct t e a bank i n Springfield,
Mass., a n d have remittance either t r Boston o r N e w York


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Federal Reserve Bank of St. Louis

“
funds a s t h e y Cheese, I

think t h e r e c o u l d b e neo legal

obstacle t o our verking i t that way. Indeed, i t already
has been dene i n the past a n d i s being done n e w i n some

districts, although t e « limited extent only.
Geverner Seay. That is, sending yeur cwn checks o r
checks received frem yeur o w n member banks.

T h e sericus

objecticn would come from the member bank, a s I take it,
which might b e oppesed t o direct sendings because t h e
checks w o u l d r e a c h t h e m o n e d a y sconer,
Mr. Harrisen.

T h e a n s w e r w e u l d b e this: p e r h a p s

the greatest bulk or their own items that they are sending to the reserve banks are en the same scaedulegna that
they are n o w receiving o n e d a y earlier credit,

o n the

bulk e f their o w n collections f o r which they tnemselves
are suffering a n offset, o r would b e suffering a n offset
by p a y i n g e n e d a y earlier.

Governer Norris. B u t suppose i t is not a member bank,
Mr. Harrison. I

think fhe majority c f the nenemember

banks g e t t h e benefit e f thet o n e d a y saving o n e w a y o r
another.
Governor Seay. I

de net think a s a

that t h e r e e x i s t s t h a t right.

matter

c f law


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Mr. Harrison. Y o u d e net think what, Gevernor Seay?
Gevernor Seay. T h a t a s a matter o f fact a Federal
reserve b a n k c f o n e d i s t r i c t c a n f o r w a r d i t s c h e c k s f o r
collection d i r e c t l y t e a
There i s r o o m f o r a

member b a n k i n another district.

difference

c f opinion.

W e d e net

think t h e right exists,
Mr. Harrison. I

er the cther, I

d e n e t t h i n k i t i s clear-cut a n e w a y

agree, b u t m y thought i s , having a c k tend

in eur o w n mind that i t i s legal f e r u s t e act a s the
agent o f the Federad Roserve B a n k o f Boston, a n d the
Springfield b a n k would cbject e n d s a y that w e have n o legal
authority, t h e n would come t h e question i n the court a s
to whether o r not Beston could autherize u s a s their
agent t e send direct.
Gevernor Seay. B u t could y o u act a s agent f o r t h e
Federal Reserve B a n k o f Boston w h e n y o u are forwarding yeur
own checks?

I

f y e u were forwarding something t h a t came

te yeu from t h e Federal Reserve R a n k o f Bosten--but h o w
could y e u f o r w a r d y o u r o w n c h e c k s a n d a c t a s t h e i r a g e n t ?
Mr. Harrisen.

B e c a u s e t h o s e checks a r e checks w h i c h

ctherwilse w e w o u l d s e n d t e t h e F e d e r a l R e s e r v e B a n k o f

Boston a n d have t h e m send them t e Springfield.

I f Boston


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says i n s t e a d

Springfield,

e f sending

t h e m t e u s t o ferwerd

t a

s e n d t h e n C i r e c t f o r o u r account.

Gevernor Seay. T h a t i s true, b u t t h e y a r e y o u r o w n
checks. I

doubt v e r y m u c h i f y o u w o u l d have, u n d e r t h e

act a s i t i s werded now, authority t o ferward those direct t e that member bank. B e s t o e n has n e control o v e r
then.
Governor N e r r i s . I

believe

t h e committee

opinion t h a t i t c e u l d n e t b e dene.

O n page 6

was

o f

t h e y say:

"It is quite obvious such a n arrangement could not b e
e without the
d consent o f athe paying bank,’
m
' and s e
forth.
Mr. Harrison.

Y e u can d e a

let b y this principle

of agency, previded i t dees not vinlate seme other vested
right c f some third party. N e w a t the present t i m e w e authorize t h e Albany banks t o send direct t o Chicago items

payeble i n the Chicage district.

T h e s e items, under the

law, a r e technically suppesed t o come directly threugh
us, r a t h e r t h a n t h r o u g h t h e C h i c a g o banks,

b u t w e short-

circuit i t i n the iabavene c f expediting the collection
system.

T h e r e is a

difference

t e the third party in-

volved, a n d the third party might crject a n d bring t h e


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Federal Reserve Bank of St. Louis

matter

u p f o r t e s t i n t h e courts.

The Chairman. Gentlemen, w h e t i s yeur pleasure
with regard t e Districts 1 , 2 and 3 ?
Gevernor Seay. T h e r e i s one thing I would like t e
refer t o and that i s the fact that ouite a

bit o f embar-

Passment a r i s e s f r o m t h e facut o f c o m p e t i t i o n b e t w e e n
the
member b a n k s f e r b a n k account.

I n times p a s t w e h a v e

hed compleint f r o m the Baltimere banks that t h e Philadelphia banks w e r e willing t a take their items o n certcin places i n cur district a n d credit t h e m cne d a y sooner than they ceuld 1eceive crecit f o r that Ceposit i n
their o w n branch bank o r the i'ederal Reserve B a n k o f
Richmend.

T h e y have invited accounts o n that basis.

Where i n New York, f o r instance,

o r Philadelphia, f o r

instance, i s over night from the member banks, they
have a n advantage cover t h e member banks i n Richmond
and i n Baltimere,

a n d t h e y have solicited accounts

o n

that besis. The member banks i n Baltimore have objected.
Governor Nerris.

T h e Baltim.re banks opject t e the

competition o f Philadelphia o n a Philedelphia objects t e
the competition o f the N e w York banks.
Governor Fancher. A n d Pittsburgh objects t e


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Federal Reserve Bank of St. Louis

Philadelphia.
The Cheirman. G e n t l e m e n ,
the t h r e e g r i m i n a l s

a t o n e stroke,

teke them u p separately?
wrapped u p t e g e t h e r

s r e y e u ready t o dispatch
o r d e y e u want t o

I t is all the same preblem,

i n c n e bundle.

W h a t d o y o u suggest,

Mr. Strater?
Mr. Strater. I

weuld r a t h e r n e t m a k e a n y suggest-

ion, because t h e committee h e s gene a s f a r a s i t c a n
and t h i s i s l a r g e l y a

matter e f pelicy, s o m e t h i n g w h i c h

the Gevernors r e a l l y should decide.
The Chairman.

D c y o u think there i s anything i n m y

suggestion o f l o c k i n g f o r s e m e s h e r t c u t s w i t h t h e i d e a

af speeding u v collections i n the three districts?
Mr. Slater. Outside o f what t h e ccmmittee h a s already
suggested I

really could n e t s e e that anything m u c h c a n

be accemplished.

T h e committee o f course weuld b e very

glad, I

t e render w h a t e v e r a i d a n d a s s i s t a n c e

a m sure,

it can, b u t i t seems t o m e that t h e preblem really lies
with t h e m a n a g e m e n t

The Chairman. I

c f t h e t h r e e b a n k s cencerned.

den't suppese t h e banks i n the

other cistricts complain w h e n they get credit a

earlier o f their items, d e they?

day


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202
Mr. Strater. N o , b u t a s a matter o f fact dotthe
banks i n the other districts h a v e t h a t adventage?
Governor F a n c h e r .

S o m e o f them complain

i f they

have t o p a y them a day earlier.
Mr. Strater.

T h e banks i n the Cleveland district

cannot v e r y well s e n d N e w England checks tre New York.
That i s prehibited under t h e previsicons o f the act. T h e y
can get n e benefit c u t o f the time schedule a s i t applies
to edjeining districts.
The Chairman.

W e have a n inter-district fleat o f

$16,000,000, a n d al? thet means i s that w e have given
the other reserve banks credit f o r $26,009,000 a

day

earlier t h e n they c a n collect t h e checks within c u r district, d e e s i t not?
Mr. Harrison. N e .

I t means t h a t c u r member banks

get the benefit c f that.
The Chairman. P h e n w e shall n o t raise t h e question.

Mr. Harrison. I

have given cur platferm, a s I see

it, and that i s that w e shculd attempt t o ultimately-I de net know h o w socn-<adjust t h e time schecules c f

the reserve b a n k s t
o © peint where they give credit cnly
for t h e t i m e t h a t i s t a k e n t e e c l l e c t t h e c h e c k s

« n the


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average, t h a t w e should attempt t e d e that before
changing c u r two-day schedule t o a three-day schedule,
and cause t h e resulting hernets! n e s t that I
would b e raised a s a result c f that.

a m sure

I n cther words,

we ought t o de two things before w e d a it. First, s e e
whether i t i s practical t o d c what t h e committee suggests
we might t r y with the consent o f the paying banks i n other

districts, send direct t e those banks and thereby collect
the majority o f the items i n these other districts actually i n twe days; a n d i f it i s impossible t o do that,
then I

think t h e q u e s t i o n b e c e m e s a

System question,

t e

see whether we want te admit tot only to New England
and the eleven Nertheastern States, b u t t e all the

country, that w e h a v e aslow, c u m b e r s o m e d
n
a inefftcient
enllection system merely because o f these arbitrary |

district lines and see whether i n the process o f time-maybe n e t t h i s year, but. whenever

i t i s feasible--1t

wont be wise te go tc Congress with a view of changing
the .colleetion system and inaugurating o r attempting
i n a u g u rr adopting
a t i
c n seme
g
sort.of collection function
that. would work irrespective o f district lines. I de,

net think .the time is ripe yet, and there will be less


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204
objecticn e n the part e f member banks. I

feresee c b -

jection e n t h e p e r t e f s o m e o f t h e r e s e r v e b a n k s ,

very properly. b u t clearly,

and

i f Cengress h a d been devis-

ing a collection system a n d not a reserve system,

it

would n e v e r h a v e m a d e t h e s e d i s t r i c t l i n e s a s t h e y h a v e

meade them a n d limited t h e collection facilities t e are
bitrary, g e c g r a p h i c a l l i m i t s , t h a t w e r k « a hardship

cn

these districts which are the most eengested banking
areas c f t h e ceuntry.

New, a s I have said, i t works practically a l l right
eut West because t h e districts a r e s e large that t h e y
ean send direct t e all over night peints, b u t because
ef o u r e x t e n s i v e b a n k i n g r e s o u r c e s a n d t h e n e c e s s i t y f e r

congested district lines, geographically,

i n the North-

east, w e have a t the same time a n erbitrarily a n d unnecessepily limited collection line, o r lines, a n d I hate
te stir u p ell t h e trouble t h a t I

think weuld arise i n

the Nertheast i f w e gave u p t h e two-day peints, withcut first being certain--fer this cencerns t h e System
as a

whele a n d n e t m e r e l y t h e t h r e e n e r t h e a s t e r n b a n k s - -

thet there might n o t b e seme advantage i n a general r e e
erganizetion o f the eellecticon system i n a way that will


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205
adapt t h e c o l i e c t i o n S y s t e m t c ' .

needs r a t h e r t h a n

te t h e c r e d i t needs.

Governor Seay. Mr. Chairman, p l a i n l y t h e committee
has gene just a s far a s i t c a n g o a n d has discharged i n
& most e f f e c t i v e m a n n e r i t s duties.
mé,

I t i s plain t e

a t least, t h a t w e c a n n e t c e m e tec a n y a g r e e m e n t

as to

changing tho Buetbnt conditicns witheut further deliberations. I

concur i
n what Mr. Harrison h a s said. I

am

profoundly convinced t h a t there i s nething w e c a n d o a t

the present. time t c bring abeut the desired end. There-~
fore I move that t h e repert e f the committee b e accepted,
be received a n d filed ane stucted,

a r d that this Confer-

ence extend i t s thanks t e the varicus members. ef t h e
committee f o r t h e f r e x t r e m e l y e f f e c t i v e w e r k .

Governor Harding. I will second that meticn.
The Chairman. I s there any further discussion?

(There was ne further ciscussicn, and the motion,
having b e e n d u l y secended,

The Chairman.

w a s u n a n i m e u s l y carried.)

W e have n o t finished consideratton

of the whcle repert i n detail.

W e have read it, and

are prepared t e adopt i t s recemmendations,
stand: 1%.

D

a s I under-

e y e u w i s h t e censider a n y orecedure w i t h


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206
the F e d e r a l R e s e r v e F o a r d i n d e a l i n g w i t h t h i s n e w t i m e
schedule a n d t h e i n e q u a l i t i e s w h i c h a r e p r e s e n t e d a n d

discussed i n the report, because t h e adoption o f a new
time s c h e d u l e r e q u i r e s a c t i o n b y t h e F e d e r a l R e s e r v e

Board?
Gevernor Talley.
is making a

study o f the fleat a t the present time.

The Chairman.
the repert,

T h e Beard has indicated that i t

W e u l d i t b e proper, having adopted

t c ask the Standing Committee c n Cellections

to take i t u p with t h e Federal Reserve Board a n d t e d o
whatever i t thinks i s necessary i n connecticn with 4 t ?
Governor Harding. I

did net understand that w e had

adopted t h e report, b u t merely that i t had been accepted
and filed.

Gevernor Seay, Accepted and filed fer study, a n d
I will add t o that that a copy o f it be submitted t e the
Federal Reserve Board.

Governer Wellbern. I think it would be a goed idea
te s u b m i t t h e i d e a e x p r e s s e d

b y Mr, H a r r i s o n ,

t h a t is,

the pessibility o f going before Congress a n d getting a n
amendment t o éffecffacbcientific ceellection system. I
think w e s h e u l d c o n s i d e r t h a t .


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207
The Chairman,

T h e m i n u t e w e attempt t h a t n o w w e

are going t o have t h e whele p a r collection business coming
up again.
Gevernor Wellbern. I
Objection

doe net think there i s s e much

t e it.

The Chairman.

T e t h e p a r eellection system?

Gevernor Wellborn. I

never hear very much about that,

only from a certain group that prought these suits.
The Chairman. T h e r e a r e about 1200 banks d o w n i n your

country that are raising cain all the time.
Governer W e l l b o r n .

Twelve hundred

c f them?

The Chairman. A r e there 1ct?

Governor Wellbern.

N e , abeut three.

The Chairman. H o w many d i d y e u have i n that organized
assault o n the p a r cellecticn system?
Governor Wellborn.

along that line. I

T h e r e w a s n e concentrated effort

have never heard a

banker s a y a word

about it.
The Chairman. H a s that committee bee: disbanded?
Governor Wellbern. Yes. T h e y were a l l broken u p
when t h e Manley banks failed.
Manley business.

T h e y were a part o f that


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208
Geverner Seay. G e v e r n e r Wellbern's district i s not
new attempting a n d never has attempted t e collect c n the
bulk o f the banks i n that district,

a s i s t h e case with

all the other Federal reserve banks. I

think h e has a

limited number o f par banks i n his district.
Geverner Wellborn. A

limited number?

Governor Seay. Yes, t h e minimum number. T h a t is, I
think y o u heve fewer relatively t h a n a n y other district
in ‘the country,

Governor Wellborn.

W e have h a d a gerd many state

banks withdraw f r o m t h e System, A

very f e w o f cur nen-

member p a r remitting banks have rescinded their action.
Mr. Harrison. I
my remarks,

had heped, Geverner Wellbern,

in

t e indicate that under n e circumstancss s h e u l d

we g o t e Congress f o r a n y revision c f the l a w o n eccllectlens until after w e h a d exhausted every cther prssibility

ef impreving the System without a n amendment. I

sheuld

hepe that w e will take a sufficient time t e enable ill
the ebjecticns t e the p a r ¢cllectien system t e have
settled d o w n befere w e think o f a n y revision aleng t h e
Utopian lines that I

discussed e a few moments ago.

Governcr Wellborn. I

d o net ecnsider

i t Utcpian.


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Federal Reserve Bank of St. Louis

I think i t i s rather prectical.
Governor Harding.

A s between t h e choice o f evils

I think i t i s better t e absorb some float rather t h a n t e
advertise t h a t w e have a cuwnbersome collection machinery
which d e p r i v e s t h e b a n k s

e f getting collections

a s quick-. ©

ly as they did get them when we didn't have any callectien
system,

Gevernor Seay. E s p e c i a l l y w h e n w e have boasted about

the superiority of the system over the former method.
The Chairman.

I t i s superior. T h e r e 1 s n e question

about that.
Governor Seay. Yes.
The Chairman.

program?

A r e w e ready t e preeeed w i t h the

T h e next tepic i s 2-D, direct sendings o f

cash letters.
II. C o l l e c t i o n s a n d Clearings.

D. Direct Sendings c f Cash Letters.
It i s suggested that e a c h Federal
reserve b a n k m a k e a

survey a n d r e +

port o n the questicns ( a ) whether
it i s receiving t o c many cash letters p e r d a y from a n y one direct

sending member bank e f anether dis«
trict, a n d (b) whether a n y c f its
ewn member banks a r e making a practice o f sending daily letters o f

trifling ameunts direct t o Federal
tfeserve banks c f cther cistricts.


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210
The Chairman. T h a t topic w a s suggested b y a
statement m a c e t o m e b y Governor Young,

i n which h e said,

speaking f r o m memcry, t h e t t h e y were doncks t h 1 8 0 0
cash letters a

d a y o u t there.

I s that a

fatr s t a t e m e n t ,

Geverner G e e r y ?

Governor Geery. I

cannot tell y o u about t h e tetal,

but just for tllustration, o n uctober ist w e received
52 cash letters f r o m the Chatham a n d Phoenix a d totied
Bank o f N e w York for tmmedfate

opel

T h e t means bicke

drawh o n St.Paul a n d Minneapelis.

The Cheirman. T h i r t y two?
Gevernor Geery. T h i r t y two. H i t h e r o n e c f twe
things h a s happened.
department m a k e s a

E i t h e r every time their e e n e r s

run t h e y wrap i t -

a n d make I f a

letter a n d send i t cout, o r else c a c h one c f their branches
sehds o u t a

tronedt L E T T er.

The Chairman. T h a t t s what happens,

Governor Geery.

B u t here i s the week beginning

October 3rd. W M e n d a y we had 32 lhngidata credit l e ters,
Tuesday ll, Wednesday 22, Thursday 12, Friday 14.
Mr. Harrison.

A l l from t h e Chatham a n d Phoenix Bank?

Governor G e e r y . Y e s .

we 205-7, 1 3 , 1 1 and 9 .
et

F r o m t h e B a n k o f Manhattan

S o m e e f these letters a r e


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Federal Reserve Bank of St. Louis

ein
petty items.

U n e letter f o r immediate credit o f

$5.60 from the Chatham and Pheenix Bank. A

half a dezen

were $57, $59, a n d $67, $76, $14, and $67.
The Chairman. T h e topic w a s placed o n the program
in order t e develep this v e r y thing.

A r e there a n y

other districts t h a t have h a d experience similar t e that
of ‘inneapclis?

Geverner Seay. T h e r e i s nothing t e complain o f o n
the p a r t o f t h e R i c h m e n d bank.

Gevernor McDeugal.

O f the direct sending banks

lecated i n New Yerk City there a r e twenty eight which
appear t c b e sending c u t more c a s h letters t h a n neces-

sary.

T h e y send u s a n average o f 144 deferred letters

and 110 immediate credit letters e v e r y day.

W e seemingly

get mere letters than necessary from the New York banks.
The Chairman.

I t i s prebably explained

i n all cases

by the branches sending direct.
Governor McDeugal. That I de net know.
Geverner Geery. T h a t dees n c t apply t e the National
City Bank.

T h e y have a number c f branches.

The Chairman. A n d they send only c n e letter?
Governer G e e r y .y -T h e y s e n d f o u r

o r five.


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Federal Reserve Bank of St. Louis

212
Governor Herding.

W o u l d i t b e possible t o limit

direct sendings t e items e f certain amount?
The Cheirman. I

think i t cught t e b e dene i n some

Gevernor Geery- O n the other side o f the case, e f
our banks sending direct, h e r e i s one week's letter o f
the Nerthwestern Netional B a n k c f Minneapclis,
Federal Reserve B a n k e f Richmond.

t o the

T h e y senf direct a

letter each day itn amount a s follows: $88, $154, $631,
$1477, $183, o n d $985, T h e r e i s ne excuse for a member
bank sending a n $88 direct t e the Federal Reserve B a n k
ef Richmend,
Mr. Streter.

There is a

physical p r e b l e m i n v e l v e d

there, sir. Geery. Y o u will find that t h e banks i n New

York, like the banks i n all the lerger cities, have
their direct routing arrangements s e t u p mere cor less
automatically.

Y o u r bank i n Mihneapelis, f e r instance,

that sends s e many letters, might have e n cne d a y a n

$80,000 item o n Richmend and the next day a n £88 item.
The result eof thet i s that they cannot pessibly tell
until t h e clese o f the d e y what t h e y ere geing t o have
in a n y g i v e n F e d e r a l r e s e r v e bank.

I

f they wait until


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Federal Reserve Bank of St. Louis

“213
they have prepared a l i o f their letters a n d then cull
out t h e small ones, t h e y have g o t t e rehandle everything that they have already started a n d put through
the mill.

S e far a s cur bank i s cencerned i t deesn't

make a particle o f difference whether w e get o n e letter
or twenty.

W e consider i t quite a simpie matter t o

put twenty letters through the mail.
putting down a few more figures.

I t just means

O u r transit man teld

me the other d a y h e would lots rather g e t t e n letters

of $200 than cne o f $20,000, because i t is much casier
te verify ond fellow through 2 number c f small letters
than i t is one large one.
The Chairman.

A t the Conference i n November

1925 there was a discussion of this, resulting i r
resolution which was passec, indicating thet each Federal reserve b a n k could take u p with a n y member bank,
guilty o f sending trifling items, t a k e i t u p with thet
bank a n d c o r r e c t i t . I
hewever,

notice w i t h s e m e amusement,

t h a t Geverner Y e u n g w a s t h e o n l y c n e w h e v e t e d

against that. Hewever, I

de net believe that any bank

in New York sheuld send direct a n item o f $11.14.
seems t o m e t h a t i s e n a b u s e o f t h e p r i v i l e g e

I t

c f direct


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Federal Reserve Bank of St. Louis

sending.
Mr. Herrisen.

M r . S t r e t e r a n s yered t h a t q u e s t -

ion v e r y s a t i s f a c t o r i l y f r o m m y pceint o f
vicw when h e
said t h e t i f a

bank sheula w e i t u n t i l t h e l a s t
minute

to find c u t whether e r not i t
sheuld b e sent @irect
or s e n t

t o the Federal reserve

b a n k that

i t weule i n -

volve double handling a t the
lest minute e f all these
letters, which, a t the last minute,
t h e y found o u t
were n e t b i g eneugh t e g n direct.

W e feel i n New Yerk

best w a y t e d e w o u l d b e t e l e t
t h e matter g e
unless c h r o n i c a l l y a

bank c r b r a n c h i s s e n d -

ing t e e m a n y s m a l l letters, w h i c h
indicates t h a t a

benk hasn't get a sufficient velume
o f items e n a given
peint t o justify direct sending.

T h e y sheuld i n that

case s e n d t o the Federal reserve
bank.
it 1 s ecenstant a n a chronic,

B u t unless

w e think the best thing

to d e i s t e let them g o threugh,
e v e n i f t + dasa
respit

i n seme eases

t o which Gevernor G e e r y
has re-

ferred, where t h e items a p e
quite small.
Mr. Strater.

T h e thing will have «
tendency

to c o r r e c t i t s e l f , b e c a u s e

i t 4 s exncnsive

t e send


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Federal Reserve Bank of St. Louis

21S
a l o t o f s m a l l letters.

I t seems

t o m e t h a t i f anyene

called their attention tec the apparent abuse
o f the

Cirect sending privilege, a n d would peint cut
t e the
member bank thet i t i s costing t h e m t e e much
t e eollect
items f r e m certain points b y sending direct, e n d
that

it weuld b e more t e their advantage t e cut dewn
their
direct sendings and pick cut these points where
they dc
not have very many items, climinete these peints f r o m
Cirect sending a n d include t h e m i n the cash letter
to
us, t h a t t h e y w o n l d b e v e r y g l a d t e h a v e
t h e suggestion
made,

a n d t h a t i t w e u l d t a t e c a r e o f i t s e l f naturally.

Geverncr Seay.

I t i s evident that w e cevered t h e

matter b a c k i n 1925, a s w e understeod t h e situation
then,
as well a s i t could b e dane,

I t i s « metter c f pure

mechenies w h e n onee a direct reute h a s b e e n established,
It i s then carried o u t b y miner clerks i n the transit
department, a n d until attentien i s called b y the
reserve

bank t e the other effending reserve bank o r offending
member b a n k i n ancther district, nething c a n b e done.
I think i n t h e t r e s c l u t i e n

w e heve cone 2 8 near a

solution


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Federal Reserve Bank of St. Louis

of { t a s w e c a n get.
Governor Harding. I
submit, w h i c h I

have o n e other suggestion t e

think obviates t h e mechanical sugzesticn

which "ny, Strater reises. S u p p e s e direct sending were
limited.in this wey, t h a t there sheuld b e n o direct sending e f a n y i t e m l e s s t h a n $500.

T h e n a n y bank getting

an item ¢ f $2.40 would p u t i t i n one pigeen hole, t e g o

te the Federal reserve bank, a n d i f it gets a $500 item
it g e e s

i n another o l g e e n hele,

a n d tn: that: w a v e a l )

o f

the little items will g e t e the Feceral reserve b a n k
and there wont b e a n y harcship i n that.
Governor McDougal. O u r preeecdure conferns t e the

recommendation c f the committee o n ccllectiong, a s sume
marized i n paragraph 2 9 o f the Secretary's minutes o f
November Conference, 1925.

T h e committee expressed t h e

opinien that there should b e n o limit placed o n the
dollar amount c f cash items t h a t a
rect.

bank might s e n d di-

A n d where i t appears t h a t a direct sending member

bank sends more letters e a c h d a y than should b e necessary, o r a s a regular practice sends letters o f trifling
amounts, t h e Federal reserve b a n k c f the district i n which


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Federal Reserve Bank of St. Louis

out
said m e m b e r b a n k i s l o c a t e d s h a l l t a k e t h e m a t t e r
with thé. b a n k i n q u e s t i o n a n d e n d e a v e r

The Chairman.

t e recrncile i t .

T h a t i s the minute I

moment ago, Governor McDeugal.

up

referred t e a

N e w , there a r e three

courses that have been suggested o r inti,ated. O n e i s
the action propesed a t the former meeting o f the Conference i n November, 1925,under which t h e reserve
banks shall call each cther's attentien t e abuses; t h e
second i s toe adept some practice s u c h a s Governor
Herding suggests a n d limit t h e ameunt, splitting t h e
letters between t h e Federal reserve b a n k a n d the direct
sendings;

a n d t h e third w o u l d b e t e refer t h i s subject

to t h e c o m m i t t e e a n d a s k t h e m t e s e c u r e m o r e d a t a t h a n

we have here a n d submit «
until t h e n e x t Conference.

formula, without waiting
T t t9 a

cauesticn o t w h e n

course t o pursue.

Gevernor Seay. I

believe t h e Standing Committee

on Collections m a d e a very complete s t u d y o f this matter
in 1925.

T h e recommendation w h i c h t h e y t h e n made con«

forms t o what I

know i s the experience o f our o w n bank,

and I deubt i f any of us can g o any further than that.
I will move, $M3 r . Chairman,

t h a t w e refer t e t h e


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recommendations of the Standing Committee cn Collections ,
made i n November o f 1925, a n d fallow t h e practice there
recommended.

Governor McDougal. I
The Chairman,

will second that metion.

Y e u understand t h a t t h e o n l y cemplaint

that I know o f paving been made t c us was the statement
ef Gevernor Young some time ago, which resulted i n this
topic being placed c n the pregram. T h e idea i s that these
abuses w i l l b e reported more frequently a n d mere prompily
and taken up.

I s that t h e ides?

Governor Seay. T h a t i s the idea.
Governor Talley. I

think i t w o u l d b e b e t t e r f o r t h e

complaining F e d e r a l r e s e r v e b a n k t o t a k e i t u p d i r e c t l y

with t h e Federal reserve banks e f the other districts
rather t h a n with its members.
The Chairman. T h a t i s what I mean, a

matter between

the Federal reserve banks entirely.
(The motion, having b e e n duly seconded, w a s unanimously carried.)
Governor Harding. I

should like t e b e recorded a s


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not voting.
The Chairman. Now, gentlemen, I

call your atten-

ticn t e the fact that three tepics, III-A, I I I - B a n d
III-C, h a v e a l l b e e n d e a l t w i t h w h i l e M r . M i l l s w a s

here.

T h e next i s IV, t h e Board's regulations, a n d

this must b e dealt w i t h after w e have read them.
Topic E V - B remains c n the program f r o m the former

Conference, a n d i s raised again b y the Beard's letter
X-4957. I
dressed.

a m not sure t e what bank that letter w a s a d e
T h e topic raises t h e inquiry o n reimburse-

ment o f expenses rendered Government agencics.
Governor Norris.
The Chairman.

I t was Philadelphia, M r . Chairman.

W i l l y o u discuss t h a t , p l e a s e ,

Governor Norris?
IVs. Operation a n d Administration.
B. Reimbursement o f Federal reserve
banks for expenses c f services rendered f o r Gevernmental agencies.
Geverner Norris.

A t the last Governors! Conference,

the auestion w a s raised whether t h e Federal reserve
banks s h e u l d n o t b e r e i m b u r s e d

b y Federal l a n d b a n k s

for expense involved i n paying Federal f a r m loan coupons.
Governor S e a y moved that t h e y should b e reimbursed,
and Gevernor Talley amended b y suggesting t h a t they b e


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220
reimbursed
serve bank.

i f a n d when requested

b y the Federal r e -

A f t e r s o m e discussion u p o n t h e volume c f

these services, a n d the cost o f rendering them,
Governor S e a y stated t h a t his principal purpose w a s t o
get t h e opinien o f the Conference a s t o whether i t
was n o t a correct principle that reserve banks sheuld,
as a

rule,

b e reimbursed f o r services w h i c h t h e y render-

ed t e other governmental agencies w h i c h were sustained
by their o w n income.
A motion was finally -ffered b y Gcevernor Calkins

that "In principle, t h e Federal reserve banks should b e
reimbursed f o r services performed f o r goverrmental agencies o t h e r t h a n t h e Treasury,

w h e n t h e expense i s suffi-

cient toa justify t h e filing o f a claim b y the individual
bank concerned."

T h i s substitute m e t i o n w a s accepted

by Governer Seay, a n d adopted.
Under date o f June 24, 1927, b y letter X-4887, t h e
Federnl Reserve Board advised t h e Governors t h a t i t
was n o t i n harmeny with this view.
After receiving that letter I
Crissinger, a c k n o w l e d g i n g r e c e i p t

wrote t e Governor
o f t h e letter,

and

inquiring whether i t would b e i n order t e ask why the


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221,
Board was n o t i n harmony with t h e resolution adopted
by t h e Conference.

T h a t w a s n o t a n s w e r e d apparently.

I wound u p that l e t t e r b y saying " I have taken t h e
liberty o f stating these considerations a t some length
because w h i l e t h e i m m e d i a t e m a t t e r

i s o f small import ~

ance, t h e principle involved i s e f very great importance.

I t occurs t o m e that possibly a l l o f these i m -

plications w e r e n o t f u l l y c e n s i d e r e d

b y the Board pricr

to the action stated i n your letter X-4837.

I f the

conelusicn stated 1 n that letter i s the considered judg-

ment c f the Board, I tnink that the matter would b e

worth discussing a t the Joint Conference next fall."
it was i n answer apparently t o that letter that this
subject w a s put o n the program.
Governor Wellborn.

D i d y e u get a

reply t e your

letter?

Governor Norris. S i m p l y a reply i n the way o f
putting t h e subject o n the program f e r discussion.

Governor Wellborn. B u t they did not give any reasons f o r t h e i r c o n c l u s i o n ?
Gevernor N o r r i s .

The Chairman.

N o n e whatever.

W e have had about a s much o f that,


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B22
if not more, t h a n a n y other bank, possibly, w i t h the
exception o f Minneaplis.
Governor Bailey. M r . Chairman, t h e pelicy c f the
Federal l a n d banks i n calling their bends f o r redemption
before d u e date i s causing considerable confusion f n
redeeming t h e coupens clipped f r o m Federal L a n d Bank
bonds.

There f s outstanding a large number o f these bends
of the various serfes that have not been presented for
redemption,

a n d i t i s necessary f o r t h e employees hand-

ling coupons t o check each coupon against various lists
received f r o m the different Federal l e n d banks,
We are i n receipt o f a ietter f r o m the Federal
Land Bank o f St.Paul regarding coupon redemption, a n d
there i s quoted below a portion o f tneir letter:

"Due t e the fact that some o f the Federal
reserve banks have transmitted coupons t h a t should
riot have b e e n paid w e have a

request t o make a n d

that i s that the coupons b e forwarded t o us i n the
original envelopes i n which t h e y are delivered t o
the Federal Reserve B a n k o r its branches, bearing
the n a m e o f t h e d e p o s i t o r

o r correspondent

o f such


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‘bank o r branch,

a n d also t h e number

o r initial

of the clerk b y whom t h e ceupens a r e checked in.
If a n improper i t e m 4 s then cashed a n d forwarded
to us, i t c a n b e r e t u r n e d

i n the s a m e envelope

and the forwarding bank o r branch will i n turn
be able t o recover f r o m its correspondent a n d
sustain n o loss.

G r e a t e r c a r e i n handling t h e s e

coupons will n e deubt b e taken i f the clerk has
to affix his number o r initial t o the envelope.
We hope that a l l Federal reserve banks a r e willing
to cooperate w i t h u s i n this manner, a n d w e assure
you t h a t s u c h e c o p e r a t i c n w i l l b e g r e a t l y a p p r e -

ciated.”
The request o f the St.Paul b a n k 1 s impessible,

as

our member banks forward these coupons t o u s listed o n
a coupen schedule a s t e denominations, a n d d o not attempt
to list e a c h Federal l a n d bank coupon separately.
As t h e r e d e m p t i o n o f Federal l a n d b a n k b o n d s

and coupons i s becoming more a n d more complex, a n d the
volume will n e deubt t e n d t e increase,

i t seems o n l y

fair that t h e Federal reserve banks should cbtain

some relief either b y being reimbursed for clerk hire,


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or a change i n the method o f handling.
Governor Harding (after discussion).

M r . Chairman,

I meve t h a t i n t h e o p i n i c n o f t h i s C e n f e r e n c e t h a t i n

cases where a n y Federal reserve banks incur a n y unusual
or.substential e x p e n s e

i n rendering services

t o any

bureau or.agency o f the Treasury e f the United States,
that it- is p r e p e r f o r s u c h b a n k s

t o submit d i r e c t

to

the T r e a s u r y any. c l a i m f o r r e i m b u r s e m e n t w h i c h i t m a y

make.
The Chairman. Governor Harding,

a t the M a y meeting

of 1927, w h e n t h e question came u p a s t o the expense cof
paying F e d e r a l l a n d b a n k coupons,
out disapproval,

i t w a s voted, w i t h -

t h a t i t was t h e sense o f the Conference

that i n principle t h e F e d e r a l r e s e r v e b a n k s s h o u l d b e
reimbursed f o r s e r v i c e s p e r f o r m e d f o r g e v e r n m e n t a l

agenctes o t h e r t h a n the Treasury when t h e expense involved

is suffictent t o justify such bank asking for neimbursement.

N o w the Beard says i n their letter that t h e y

were n o t i n h a r m o n y w i t h that.

T h e Beard does n o t as-

sert a n y jurisdiction over t h e question,
Governor Harding (after discussicn). T h i s i s merely
reaffirming that, Mr. Chairman.


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Federal Reserve Bank of St. Louis

225
The Chairman.

M r . Harrison tells m e that this w a s

not s u b m i t t e d t o t h e B o a r d b u t t h e y s i m p l y r e a d i t i n
the minutes.

T h e Board h a s simpiy expressed t h e view

that i t was o u t o f sympathy, a n d I

do not believe i t

gave much consideration t o it. G o v e r n o r Harding's
motion n o w i s t o reiterate t h e a c t i o n t a k e n b y t h e C o n -

ference ttn May o f 1927.
Governor Harding. T h a t t h e Conference reaffirms a n d
reiterates t h e action e f the Conference t a k e n i n May,
1927, a n d believes

i t i s e n t i r e l y p r o p e r f o r a n y Fed-

eral reserve bank, performing a n y services f o r a n y governmental agency, t o claim reimbursement f o r such expense.
Governor Wellborn. I

will s e c o n d that.

(The motion, having b e e n duly seconded, w a s carried.)

The Chairman. Gentlemen, i t is time t o recess for
lunch.
(Whereupon,

a t 1.05 etclock p.m-, u p o n motion

duly seconded, a

recess w a s taken until

2.15 o'clock p.m. o f the same day.)


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AFTER RECESS.
The hearing w a s resumed a t 2.30 p.m.

The Chairman. T h e meeting will come t o order and
we will proceed toe Topic IV-C, suggested b y Philadelphia.
Governor Norris?
IV. O p e r a t i o n a n d Administration.

Cc, Standardization o r abandenment o f
Functional Expense Reports.
Gevernor Norris.
reports.

T h a t I s the functional expense

W h e n t h e system o f making t h e s e functional

expense reports w a s started, I

was quite strongly i n

favor o f it- I n fact, I think that Dr. Miller and I
were t w o o f the members o f the first committee o n the
subject.

T h e r e were some changes made afterwards, a n d

I stili stuck o u t f o r their value after I

think a good

many othefs h a d lost a n y opinion that t h e y ever h a d o f
their valve.
Now, i t has been going o n for h o w long--four years?

If it is net four years i t ts about four. I

think i t

started i n 1923 o p 1924, a n d I recently compared the
figures a s t o where unit costs a r e given, w h i c h presumably a r e t h e most definite, taking c o i n counting,

where the cost i n the highest cost bank i s over three


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times t h a t i n t h e lowest.

I

n city c h e c k clearings

the highest i s three times t h e lowest:and t h e lowest i s

only one half o f the average.

I n check collection,

city checks, t h e highest i s nine times t h e lowest a n d
the lowest i s two thirds o f the average.

I n Government

checks the highest i s three and one half times the lowest
and the lowest 1 s only one half o f the average.

I n

country checks outgoing, t h e highest i s more t h a n three
times t h e lowest a n d the lowest i s one half o f the average.
In non-cash collections, city, t h e highest i s five times
the lewest a n d the Lowest i s only a little over o n e third
the average, altheugh that i s n o t a fair comparison, b e cause t h e lawest there i s Minneapolis,

a t a time when

they were n o t doing that business.
Governor Harding.

D

o you think a n y o f those a r e

comparable basis?

Governor Norris.
ures that I a m giving.

Y o u can judge that from the figI n non-cash collections, country,

the highest i s nearly four times t h e lowest, a n d the
lewest i s hald t h e average.

I

n coupon collections

ether than Government, t h e highest i s three times the
lewest and the lewest i s half e f the average.

I n


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Governmert coupons, t h e hignest i s three times t h e

lowest, and the lowest a little over half of the average.
In loans, rediscounts a n d acceptances, discounts a n d
recerds, t h e highest i s nearly four times t h e lowest

and the lowest i s less than half of the average.

I n

counting currency, the dirferences run from .052 to
064.

T h e r e t h e evidence i s that t h e cost i s o n a come

parable basis.
uf course, discrepancies w e r e inevitable i n the
beginning o f the thing. a h d after a

while a

mani} w a s

gotten c u t t o instruct t h e banks h o w t o make these calculations.

S o m e a t least o f the banks a r e i n some re~-

spects paying littie o r n o attention t o that manual.
For example, t h e employees i n General Brocks' u n i t
Bestoen reports o n l y e m p l o y i n g o n e a n d c n e h a l f e m p l o y -

ees i n the last half o f 1923, a n d then t h e manual specified thet certain things, f r o m four t o eleven things,
should b e grouped under that heading, b u t t h e inclusion
or the failure t o include a l l e f those things h a s o n l y
brought Boston u p from 1.50 t o 1.95, t h e general average
being 4.18.
I de not give a n y o f these figures b y way o f re-


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229
flection o n any bank, o r eritigism, b u t o n l y a s evi-~
dence that t h e manual i s not being followed, t h a t t h e
results « r e not comparable:
Now, I

asked t h e a s s i s t a n t c a s h i e r

i n charge o f

our accounting t o give m e a n estimate o f the cosv t o us
of making u p these functional reports, a n d h e replies,
anong o t h e r things, t h a t i t i s n e c e s s a r y

t e keep dally

reports i n some fifteen departments o f the bank i n order

that, a t periodical times, a report may be furnished t o
our accounting departmert, where t h e actual final repert
is prepared, s h o w i n g t h e v o l u m e

or pieces.

o f work handled

i n numbers

T h e time represented i s approximately equiva-

lent t e that o f three persons f o r each working d a y i n the

year, a n d figuring this e n a n average salary basis the
cest t o us i s about $4,300 a year.
I find a s a rule our figures o n almost anything represents about o n e tenth o f the System,

s o that w e would

suppese thet i t was costing the System somewhere between
$40,000 and $50,000 a year.
It seems perfectly obvious t o m e that i t i s net worth

$40,000 o r $50,000 a year t o the System to keep up the


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making o f t h e s e r e p o r t s , w h i c h a r e n e t p r e p a r e d
made o n t h e s a m e basis,

a n d a r e t h e r e f o r e n e t comparable,

and b y w a y o f b r i n g i n g t h e t h i n g t e a

this resoluticn--I

or

head I

would o f f e r

a m net particular about t h e werding

oY it, b u t this. i s . a drafts

"Whereas, t h e making o f the functional expense
reports i s cesting t h e Federal reserve banks a

sum

which may be estimated a s between £40,000 and $50,000
a yeor; a n d

Whereas, t t has not been found practicable t e
assemble t h e figures o f these repcrts o n the same
in all t h e banks, thereby destroying their
usefulness f e r p u r p o s e s

o f comparison;

and

“Whereas, t h e ineuguration c f the budget system
in all o f the banks n o w serves t h e purpose intended
to b e s e r v e d b y t h e f u n e t i o n a l e x p e n s e reperts:

"Resclved, that the Federal Reserve Beard be requested t o discentinue t h e requiring c f the making

of these reports."
Gevernor Seay. I

would like t o ask, Mr. Chairman,

if

Mr. Nerris a n d h i s officers h a v e a n y particular critcism
ef the manual, «or i s his criticism directed t a the fact


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that i t scems t e elicit different methods o f reports

and a cifferent organization i n the several banks, s o as
to r e n d e r i t i m p r a c t i c a b l e

t o get their reports

o n a

comparable basis?
Gevernor Norris. I
lies, a n d therefore I

do net know where t h e fault

do not undertake t e allocate it.

Either t h e manual 4 s defective o r the banks have chosen

to ignere the manual. I
and I

de not knew which i s the fact,

de net care, b u t t h e result i s that t h e figures

are not comparable, a n d i f they are n o t ccmparable I

can~

net s e e that t h e y are o f a n y value.
Governor Fancher. I

second t h a t motion,

i f i t has

already been seconded.
Governor Welliborn., D o n ' t y o u think t h e functional
reperts a r e beneficial t e the banks i n their c w n work,
as w e l l a s i n t h e c o m p a r i s o n w i t h o t h e r b a n k s ?

D e n ' t you

think that they tend t o bring about a better perfection?

Governor Norris. Ne, I do not.

F o r a great many

years, for almest every quarter o r half year since these
have been i n existence I quote from, the items where
we a r e h i g h e r t h a n t h e a v e r a g e

o r particularly where

we are higher t h a n Boston, because t h e conditions a r e s o


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202
similar

i n Beston a n d Philadelphia t h a t I

feel t h a t

pretty nearly t h e same average results ought tec be
worked o u t i n these t w o banks, a n d knowing t h e able w a y
in which t h e Beston bank i s run, I

want t o keep a s

close t e them a s I can: s o wherever o u r figures a r e
abeve t h e m o r o n the average, I

have b e e n i n the habit

of taking i t u p with c u r people.
Gevernor Harding. I
is the answer I
are higher, I

have done t h e same thing, a n d

have got.

I n cases where c u r fig-

have g o t a satisfactory explanation,

the system cannot b e changed, a n d s e on.
The Chairman. I

would l i k e t e r a i s e o n e q u e s t i o n

about t h i s t o p i c w h i c h I

have n o t r a i s e d neretofore,

but

Mir. Rounds, w h e h a d much t e d o with t h e crganization o f
this thing, makes this suggestion.

H e says that t h e

reperts h a v e b e e n i n operation since 1922, a n d b y this
time t h e s e i n e q u a l i t i e s s h o a l d h a v e b e e n i r e n e d c u t

tf there was a n y methed c f bringing about uniformity
ef accounting.

I t t s obvieus t h a t t h e exiscence o f uni-

formity i s sufficient t o defeat it, o r that uniformity
ts not pessible i f w e attempt t o iron i t out, a n d I
think t h e latter i s the case; b u t h e says that t h e report


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233
dees serve a useful purpose b y reason o f
the fact that
by @ reasonably uniform methed w e are enabled t o
de~
termine t h e System costs o f things l i k e transits,
and so
on, a n d that i f this i s abandoned s u c h uniformity a s
we
have i n comparing t h e ccst o f this service would b e
last.
We w o u l d a d v o c a t e c o n t i n u i n g

this report unless

some

methed c a n b e d e v i s e d f o r s u b s t i t u t i n g t h e u s e f u l f e a .

tures o f i t i n place o f such a n elaborate report,
My belief

1 s that i t would b e a

mistake

t o abanden

entirely a method o f dividing u p the expenses o f the
reserve banks s o that w e c a n report o r get some understanding o f what t s being done.
Governor Bailey.

W e get this through F o r m E e

The Ghairman. Yes, Schedule E ,
geocd plan, G o v e r n e r N o r r i s - - I

W a y would i t not
d o n o t w a n t t o inter-

with your metion prevailing.
Governor N o r r i s , I

said t h a t I

only offered t h a t m o -

to bring the matter u p for a concrete discussion, a n d
perfectly willing t o accept a n y amenduent that i s suggested t o that motion o r a n y change i n its phraseology.

Governor Wellborn. I

would offer a n amendment t o that,

that w e c a n eliminate s o m e o f these statements where t h e y


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Federal Reserve Bank of St. Louis

are n o t comparable.

Governor Norris. T h a t would eliminate 9 0 per cent
Ot 33,

Governor Welilbern., I

think there i s n e use o f

having them unless i t is comparable.
Governor N e r r i s .

I t i s net.

Gevernor Wellbern.

Y e u take m y friend from Richmend,

his bank and mine, the Atlanta bank.

N e have got so

much expense there fer offices.

T h a t is‘en account o f

the numercus branches w e have.

Y o u could n e t ccmpare

that e x p e n s e w i t h a n o t h e r b a n k w h i c h h a s o n l y o n e b r a n c h

bank, and that is all useless work. I

would not put

such a n item a s that i n the report.
The Chairman.

Y o u take a l l t h e foreign business

of the System, you have a department which spends money
er else you would abserb the e x p e n s e n
i some department
to d e whatever acceunting o r whatever w o r k i s necessary

in that connection, and we have segregated the whele
thing, a n d n o w w e have g o t a

lot o f clerks a

a

considers

able expenses There is nec basis of comparison between
the banks i n thet department, a n d i t is rather misleading
than o t h e r w i s e .


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Federal Reserve Bank of St. Louis

235

Governor Wellbcrn. I

should think w e could keep

up t h e c o s t o f t r a n s i t ‘ t e m s a n d h a n d l i n g c u r r e n e y a n d

things o f that kind.

W

e have s e n t i t t e the m e n who

have charge o f those departments, a n d i t has resulted
in our bank i n them trying t o make a
The Chairman. I

good record.

would like t o see this resalution

modified t o this extent, t h a t w e are i n favor o f abandoning the report unless t h e committee,

i n collaboration,

say with the gentlemen who work o n ite-and i t would b e
Mr. Smead a n d Mr. Rounds=«can devise o r simplify «
method which would accomplish t h e results which a r e
still o f value.
By t h e way, M r . J a m e s a s k e d m e a t l u n c h i f w e w o u l d

not get Mr. Smead i n te discuss this metter, a n d I had
everlecked i t entirely. I

think w e cught t e de that,

Mr. Norris.
Governor Norris. Yes.
we should; particularly,

I f h e asked you, certainly

i f w e are going t o pass a n y

resolution i n any way adverse t o the making o f these reports, w e ought t o give Mr. Smead a n opportunity t e b e
heard first.

The Chairman. W o u l d yeu be willing t o defer further


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Federal Reserve Bank of St. Louis

discussion until w e get Mr. Smead here?
Gevernor Norris. Certainly.
The Chairman.

I

n that case w e c a n g e ahead with

the next ften, wetch io<.
IV. O p e r a t i o n a n d Administraticn.
D.Report o f Leased Wire Committee.

The Chairman (continuing). B r o t h e r McDeugal, have
you a report t e make?
Governor McDeugal. I

have a repert which has been

submitted a n d I think passed around b y the Secretary.
The Chairman. W h a t t s your pleasure?
Gevernor Nerris. I

move that i t take t h e tsual

course, whatever that is, that i t b e accepted a n d ftled.
The Chairman.

I s that seconded?

Governor Talley.

W h a t w a s t h e inciease

i n t h e volume?

Seven a r d

The Chairman. /Seven-tenths p e r cent, due principally
to fiscal agency operations.
Gevernor Talley. I
not s o m e o p p o r t u n i t y

merely wanted t o a s k i f there was

t e restore s a m e o f t h e service

to

the leased wire which were formerly performed a n d later
taken out. N e c e s s a r i l y that question w a s based o n the
assumption that t h e volume, through t h e coding o f messages,


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Federal Reserve Bank of St. Louis

37
hed declined, b u t i f the renvort itself shows a n increase
of o v e r s e v e n p e r cen’, I

will n o t g o a n y further.

The Cheirman. T h e motion i s thet t h e report b e
accepted a n d filed.
(The motion w e s p u t a n d unanimously carried.)
The report o f the Leased ‘ire Committee i s a s follows:

"Report o f leased “ire Committee.

"To the Conference o f Governors:
"Since t h e l a s t r e p o r t r e n d e r e d

b y your commit-

tee there hseve beer n o changes i n the circuits c o m prising the Leased “lire System, excepting t h e addition
of the S a n fntonio-Dalles circuit.

"Mere was a n increase o f 7.7 per cent i n the volume handled f o r the first eight months c f 1927 compered with t h e same period o f 1926. T h i s increase
wes d u e largely t o Fiscal fgency operations.

“The system i s apparently opersting satisfectorily
and the facilities

i n use eppesr t o b e ample,

"Respectfully sabmisted,
"(Signed) J . B . McDougel,

"Gheirmen, Leased “ire Committee."


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Federal Reserve Bank of St. Louis

237-8
The Chairmen. T h e ncxt i s E, t h e report o f the
Insurance C o m m i t t e e .
IV. O p e r a t i o n a n d *fdministretion.

R e p o r t s o f Insurance Committee.
Governor Norris. I

think t h e Insurance Committee

simply r e p o r t e d t h a t n o t h i n g h a d b e e n b r o u g h t

t o their a t -

tention, a n d there w a s n o t h i n g t
o report. I s a f t that t h e
mopart?

The Chairmen.
meke.

That: i
s right. T h e r e w e s n o report t o

T h e next i s Topic F , t h e report o f the Pension

Committee, e n d that h a s b e e n distributed.
IV. O p e r a t i o n e n d fdministrsetion.
F. R e p o r t

Governor Seev.

o f t h e P e n s i o n Committee.

P h e basis o f contribution h a s n o t

yet been worked out. I s thet correct, Governor Strong?
The Chairman.

tions.

I t cannot b e b e c a u s e

o f t h e saccumula-

Y o u see, t h e accumulations n o w sre v e r y large,


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Federal Reserve Bank of St. Louis

20%
and thoy have t o b e considered over t h e ectuarial life
of the payments, a n d until w e get t h e d a y fixod a n d
calculate t h e a c c r u a l s a n d t h e n s p r e a d t h o s e o v e r t h e
contributions

b y t h o b a n k a n d o f e a c h empleyce,

y o u can-

net tell what t h e centribution will be.
Governer Seay. - Do yeu know whether i t i r contem-

puatcd t o make a large lump sum contributicn i n the case
of officers w h o have b e e n with the bank a long time, o r
to make a n annual eentribution, proerata, w e will say?

Gevernor McDougal.
The Chairman. I

T h a t has net been taken up.

think the assumption has always

been that t h e amount t o b e ecntributed will b e the amount

which should have Econ provided a t the origin o f the
servic3, plus a sum t o make u p the arrears, c o te speak,
which s u m would b e approprfated o v e r t h e actuarial l i f e
of the plan t o each individual.
Geverner Seay.

o n e e f cur officers w a s i n Now York

recently a t your benk, a n d had some conversation with
Mr. Koawzel,.

and ™

understeed h i m t o s a y t o a t i t w a s

then t n contcmplation that t h e contribution i n the case
ef s u c h efficers w o u l d b e a b o u t 1 0 p e r cent.

know whether they have got that fer o r not?

D o you


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Federal Reserve Bank of St. Louis

259
Governor Fancher. I
The Chairman. I

never h e a r d o f s u c h a

Governcr McDougal.
The Chaizman.

do not think they have.
thing.

W e have n o t gotten that far.

A s i t stoed originally 1 t was slightly

6 p e r cont.

Governor McDougal.
a million dollars a
The Chairman.

I t i s going t o b e a t the

vear o r mere now.
A n d t o make u p these accruals, I

do

net know, but i t mipht b e around 4 % or © per cent.
Governor Seay.

I s i t expected that i t would b e worked

out prior t e the presentation o f the bill i n Congress?
The Chairman. Yes.
Gevernor S e a y .

The Chairman.

Governor Scay,

S e c that y o u w i l l h a v e y o u r w h o l e p l a n ?

T h e m e n have been working o n it.

t f mean, i t will b e worked out b y the

time i t i s presented t o Congress?
The Chairman. Yes.

T h a t was t h e object o f the ap-

propriation i n the last Congress. They are taking a hypothetical date i n the future t e work te, s o that the error
in the accrual will b e a s small a s possible.
Governor Seay.

What I

meant w a s chiefly,

i s it

thought t e b e necessary t o present t h e details o f the


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Federal Reserve Bank of St. Louis

plan along with the introduction o f the bill?
The Cheirmen.

O n e o f the committeemen wented t h e

deteils incorrporsted i n the bill e n d w o endeavored o r w e
ere poling t o endeavor t o pet a w e y from incorporeting a n y
detail i n the bill b y submitting i t t o the committee e s
@ sort o f » representation o f what i t involves, a n d leave t h e

deteils entirely for the discussion o f the Federal Reserve
Board,

s o thet there w o u l d b e n o materiul departure f r o m

whet i s t o b e r e n r e s e n t e d

t o t h e committee.

fre t h e r e a n y f u r t h e r r e m a r k s ?

“ h e t i s your plessure

about t h e c o m m i t t e e ' s r e p o r t ?

Governor Figgs. I

move thet i t be accepted and filed.

The Cheirman. T h e usual course, m a d e b y Governor Biggs.
seconded?
Governor Talley. I

second t h e motion.

(The motion wes put and cerried.)
The report o f the Pension Committee i s a s follows:
"Mhe r e p o r t s u b m i t t e d

a t t h e l e s t conference r e -

vivwed i n sone detail t h e history o f the Pension
Cummittee e n d i t s work.

A t that time counsel f o r

the c o m m i t t e e w a s e n g e red i n r e v i s i n g t h e p e n s i o n
bill i n c e r t a i n resnects, b e s e d u p o n c r i t i c i s m s


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Federal Reserve Bank of St. Louis

40-a

Encountered b y the originel bill i n the House C o m mittee o n Benking a n d Currency.
discussed

i n considerable d e t c i l

will not, therefore,

T h e s e chenges w e r e disc
i n thet report a n d

b e repeated now.

"Sice the last conference copies o f the revised
bill have b e e n submitted t o each o f the governors
for his individuel sugrestions o r criticism o n d
the bill i s n o w rerdy t o submit a t the opening o f the
next session o f Congress.

"In its last report the committee recommended that
there b e approprieted e n edditionsal $10,000 f o r
expenses, 2

necesssry recelculetion o f the pension

deta including secrued liabilities being contingent
upon this eppropriation.

T h e eppropriation w a s a p -

proved b y the conference a n d Subsequently b y the
Federsl Reserve Boerd. / ' 1 1 o f the banks have n o w
submitted t h e dete required b y the actueries f o r 2
recalculation u f the secrued lisbilities e n d f o r
testing t h e soundness o f the p l o n originally pro-

posed. T h e tesk o f determining the accrued lirbility


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Federal Reserve Bank of St. Louis

2£40=-b

es o f July 1 , 1927, h e s b e e n complted within t h e
lest f e w devs e n d comperes w i t h previous calculations e s follows,

e l l f i g u r e s b e i n g i n r o u n d numbers:

"Originel calculation e a o f October 1, 1920, $1,973,000
"Estimated tabulstion s s o f October

.

“ i"

"¥oetuel

a
o

9

2 6,C82,000

S e m m o r y 1 9 2 6 , 7,400,000
u

i

y 1, Vet,

8 , 1 0 0 ,00C

"It will thus b e seen that the accrued liability
continues steadily t o mount, e n d o f course t h e longer
we a r e delayed i n making the p b h operstive,

t h e

ereeter will b e the problem o f teking care o f this
liebility.

“ h i l e t h e actusries heve n o t v e t com-

pleted t h e tabulrtions f o r a complete t e s t o f the
original p l e n t o the present conditions, t h e y advise
thet t h e actuel experience appears t o justify the

original tabuletions mede, a n d i t i s believed that
no v e r y d r a s t i c c h e n g e s

i n t h e p l a n w i l l b e necessery.

"The actuery states: 'PThe check o n experience shows
thet t h e actuel number o f separations r r o m service o n
eccount o f resignetion e n d dismissrl which occurred
during t h e p a s t s i x y e r r s w a s m o r e t h e n e x p e c t e d scecord-

ing t o the rates prepared o n the besis o f the exper-


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Federal Reserve Bank of St. Louis

240e¢

lence investisation covering t h e period prior t o
1920.

T h e experience e l s o showed thet t h e deoth

r e t e s in-use e r e conservetive.~

T h e results

o f the

check o n the expericnce s h o w thet h a d t h e fund been
estoblished a t the retes o f contribution originally
set i t w o u l d t o d a y b e i n *

v e r y f a v o r e b l e position.'!

"The actueries expect t o have the dete completed
within «

very short time t o the point o f making defin-

ite recommendations e s t o the contribution retes
necessery t o b e used t o take care o f both t h e eccrued
ond c u r r é n t l i a b l l i t i e s .

Y o u r committee expects

heve o l l o f thits w o r k f i n i s h e d

to

s o 3 s t o have c o m -

plete date aveileble w h e n the bill i s introduced i n
the f o r t h c o m i n g s e s s i o n o f Congress.

"Respectfully submitted,

2. MeDougel,

"Th. R. Kenzel, Choirmen."
The Chairmen’

T h e next i s V, *. Future public

program.
V. R e l s t i o n s w i t h M e m b e r @Bsnks a n d t h e Pubdlic.
f« F u t u r e p u b l i c i t y progzam.

The Chrirmen (continuing).

T h i s i s t o b e discussed

et the Joint Conference tomorrow, according t o m y under-


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Federal Reserve Bank of St. Louis

e241

standing, a n d the revert o f the committee will now b e
distributed, a n d you are asked t e read i t before the
Joint Conference tomorrow, a n d I weuld like t o announce

that i t is arranged that the J o i n t .Conferonce will
ob bus a t 10.30 tomorrow morning.
V. R e l a t i o n s w i t h Membcor Banks a n d
the Public.
B.A s u r v e y o f t h e B a n k R e l a t i o n s D e p a r t e

ments o f the Federal reserve banks.
The Chairman.

T o p i c V - B i s a survey c f the Bank Re-

lations Department c f the Federal reserve banks, suggested

by Philadelphia.

I n anticipation o f the meeting, reperts

have been received f r o m all reserve banks a n d were distributed this morning. G o v e r n o r Norris,

discussion o f that report?

d o y o u wisn a n y

I T have net had a chance t o

read i t .

Governor Norris. N e t unless somebody else wants t o

discuss 1t. I

would only like t e s a y oword i n explana~

tion o f my reason for putting i t o n the program.
time t h a t I

did i t I

A t the

overlooked t h e f a c t t h a t i n most

of the banks that work i s n o w under t h e charge e f the
Foderal R e s e r v e Agent. I

believe t h a t i n eight O L <The

banks i t i s under t h e Federal Reserve Agent a n d i n four
under t h e Governor o r the eperating side.

W e have a


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Federal Reserve Bank of St. Louis

242

feeling that o n e c f the duties o f the senior officers
of a

reserve b a n k i s t o populrsrize t h e S y s t e m w i t h t h e

public,

a n d that that must necessarily

b e dene t o a

very

great extent, particularly outside o f the large cities,
through t h e o f f i c e r s

o f t h e member banks; t h a t i f t h e y

are i n a frame o f mind t o speak kindly o f the System a n d
of the operation o f the reserve banks i n their district,
that t h e general public sentiment i n their respective ccmmunities i s apt t o b e friendly. T h e r e f o r e ,

w e feel that

the Bank Relations Department i s mest useful a n d valuable
part o f the work.

W e feel that w e were deing i t i n a

satisfactory way, judging f r o m the results i n our o w n
district, b u t w e were anxiovs t o ascertain t o what extent

it was being dene i n cther districts, a n d i n particular
whether there was work boing denc i n othor districts a l o n g
those l i n e s t h a t w e h e d n o t t h e u g h t o f , a n d w h i c h w e
could a d v a n t a g e o u s l y adopt,

a n d i t w a s w i t h those thoughts

in mind that I put i t o n the pregram, a n d while I have
net h a d time a s yet t e study these reports, a n d while i t
is cvident that i n some minor details t h e y a r e subject
to the same criticism that I

made a

few moments a g o about

the functional expense reports, t h a t t h e y are net absolutely


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Federal Reserve Bank of St. Louis

243
comparable, I
eral c h a r a c t e r

think c n the whole, considering t h s gene
o f the auestions,that t h e y have b e e n

made u p o n very fairly comparable basis, a n d I

a m glad

to seo that pretty much all c f the banks a r e alive t o
the necessity o f the work, e n d I hope,

i n going over t h e

reports n o r e c a r e f u l l y a n d r o a l l y s t u d y i n g t h e m , w e w i l l

bu able t o get some valuable suggestions o u t o f the replies that have been made b y the other banks.
The Chairman.

W h a t a c t i c n d e y o u desire, G o v e r n o r

Norris?
Governor Norris. N o n e a t all.
The Chairman. T h e reports h a v e b e e n distributed a n d
ne action i s desired.
(At this point wr. Smead entered t h e Conference
room, )

The Chairman. Gentlemen, w e have now got Mr. Smead
hore, and, Mr. Smead, this i s the situation:
Governor Norris had a topic o n the program suggest~E
ing e reorganization o r a discentinuance c f the Schedule

report. B e f o r e you got here h e read a n analysis o f the
showcomparable unit costs 4 s reported i n that schedule,
ing the ebvious inequalivies o f the cost d u e t o different


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Federal Reserve Bank of St. Louis

244
methods o f accounting a n d s e on, a n d h e has made a calculation that i t costs t h e reserve banks somewhere between

540,000 ard $50,000 a year t e maintain these reports i n
over bank.
Much o f the material i s collected a s t h e result o f
a daily system o f reporting certain work.
question arose a s t o whether,
continued,

T h e n the

i f i t were completely dis-

w e would b e able o n even a reasonably compar-

able basis t o get t h e total aggregate costs o f the various f u n c t i o n s , w h e t h e r s e m e c o n t r o l w o u l d n o t b e lost,

end whether i n potnt o f fact there was n o t a value i n

maintaining a t least a portion o f Schedule E system o f
reporting, e v e n though a very large part o f i t was
elimineted,

s o a s t o reduce t h e cost.

I discussed this with Mr. James a t iuncheon, a n d h e

said that h e had had a talk with you about i t and pence
we called o n yeu t e come aver here.

J ] think o n a matter

cf this sort w e are very liable t o pass s n a p judgment
in passing a

resclvtion. I

a m not ready t c vote t o

abandon t h a t report.

Governor Beiley. I
The Chairman.

a m not, either.

A r d maybe s e m e o f t h e others


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Federal Reserve Bank of St. Louis

Rnel.the s a m e way; I
Gevernor S e a y .

de not know.
W e f e e l t h e s e m e way, iim. Cheirman.

Governor Bailey.

I t i s very valuable t o us.

o f

course, w e eliminate some o f the things called for.
Every t i m e w e g e t t h a t F o r m E

the h e a d o f e v e r y d e p a r t -

ment scans it, a n d w e talk i t over a t our mcrning meetings
and a lot o f i t i s eliminated because w e cannot furnish it.
But, after all, i t seems t o b e something t h a t keeps o u r
fellows i n line f o r economy a n d efficiency.

W e would

miss i t and w e do not wane t o abandon i t s o far as w e are
concerned, a n d I should certainly vote against i t s abandenment.
The Chairman,

is now.

W e l l , I

should v c t e a g a i n s t

i t as it

I f w e cculd substitute s o m e system o r some scheme

of reporting which would eliminate those things which a r e

obviously o f no value, I would b e i n favor eof that.
Governor Norris, r e a d some o f these figures t e Mr. Smead,
Governor Norris.
bound t o b e variations

M r . Smead, o f course there a r e
i n t h e c o s t o f different functions

in t h e d i f f e r e n t banks. I

of them, b u t I

wont d e t a i n y o u b y reading a l l

have here a n anelysis o f all t h e figures

where u n i t c o s t s a r e calculated. i

have n o t s e l e c t e d


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Federal Reserve Bank of St. Louis

246
any extreme cases. I

have taken t h o m all, a n d without

specifying what t h e y are, i n the first b h e highest

bank is 3-1/3 times the lowest; i n the next the highest
bank i s three times t h e lowest, a n d t h e lowest i s only
half o f the average o f the System.

i n the third the

highest b a n k i s nine times t h e lowest, a n d the lowest
is only ywo thirds c f the average f o r the System; a n d
se i t goes through t h e t e n o r twelve sectiens t h a t a r e
itemized here.
As I say, s o m e variation i s bound alweys t o exist,
and a t t h e s t a r t o f t h e systen, w h e n t h e b a s i s u p o n w h i c h

the reports w e r e t o v e made w a s n e t fully understcod,
those v a r i a t i o n s w e r e b e u n d t o b e v e r y greet;

b u t after

four years a n d the issuance o f a manuel a n d t h e assem-

bling o f these figures i n ycur Beard here and the mailing
of t h e m

t o t h e banks,

a n d s c cn,

i t would s e e m t o m e

that e n e c f two things shovid have resulted, either

that w e should get closer together e n these things a s
we are, o r that w e sheuld have t e admit that w e are
attempting t o compare things which a r e incapable o f
being compared.

Now, that frankly i s m y feeling about it. I

would


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Federal Reserve Bank of St. Louis

247
like very much, a s w e all weuld,

t o heve your views o n

it a s t e why these extreme discrepancies still exist
after four years o f attempted correction, a n d whether
you think y o u ever will b e able t o get them down t o the
same basis e f reporting.
fir. Smead. I

would b e glad te, Governor Norris.

realize e n d have right eleng that seme wide differences i n costs e r e reported t e u s o n these

W

have g o n e i n t o t h e m a t t e r

and we

o n s e v e r a l eccasions,

e

know o f céurse that t h e very wide differences w h i c h
you reac there a r e generally d u e t o ene o f the banks

having 2 large volume and another bank a very small
volume c f work.

T h a t i s n o t a l w a y s t h e case, b u t y e u

will find a geod many times where the bonk has a small
volume c f business a n d only cne o r two employees i n the
given departnent, t h a t t h e figures w i l l b e very much
out o f line a n d must necessarily b e sc.
Governor Norris.

May I

interrupt y o u f o r j u s t a

moment ? T h e a t , f o r instance, w o a l d n e t a p p l y t o c o u n t r y

I sheuld judge, where St.Louis reports t h e case
as e 2 5 e n d C h i c a g e
Vir. Swteed.

i s .629,

That

scents


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Federal Reserve Bank of St. Louis

243

Governor Norris.

end .629 f o r Chicago.

C o s t p e r unit...

. 2 5 0 for. St.Louis

N o w , Chicage must b e including

in-that c o s t some items that t h e rest a r e not including,
or St.Louis m u s t b e omitting some items that t h e others
are including, I
Mr. Smead.

should think.
Y e s ; t h o s e differences there,

i n that

particular unit, a r e much more than could b e properly
reported i f they were doing t h e same kind o f work, a n d
it must b e that there i s something wrong i n those t w o

functions. I

off~hand cannot tell what i t 4s, but these

are country checks, y o u said?
Governor Norris. T h o s e a r e country checks outgoing.
Mr.Smead. I

couldc n o t a t t e m p t

Governor Norris.
Mr. Smead.

O f course, I

t o explain that right

ynderstand that.

I t m a y b e that i t is, e s y o u say, b e -

cause t h e y are doing some werk i n thecountry check deépartment i n Chicago that t h e y are not doing i n St.Louis,
and that will have t o b e looked into; but, s o far a s
the funetional expense reports a r e cencerned,

w e here

have thought that prebably the greatest value i n those
reports would b e derived b y the Federal Reserve Banks


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Federal Reserve Bank of St. Louis

249
themselves i n comparing their costs a s reported w i t h
the costs a s reported b y other rederal reserve banks,
and where t h e character o f work done s n a given unit
or department seems t o b e t h e same, t o find o u t exactly
what w a s t h e c a u s e f o r t h e difrerence,

a n d whether o n e

bank h a d a better system t h a n the other, a n d probably
avall t h e m s e l v e s

o f that.

H o w extensively that h a s b e e n

done o f course w e have never made a n y survey t o find out,
but w e c o know i n a number o f cases v e r y merked savings
have been rade through those very means.
Whether t h e functional expense reports h a v e very

largely outlived their usefulness i s a question about
vhich a good m a n y people will very naturally have a difference o f opinion.

W

e here i n the Boerd h a v e felt

that they have i n the past served a

very valuable u s e

in the System, a n d they have b e e n o f importance i n enabling t h e banks t o cut down their expense quite materfeliy.

Most o f the banks I imagine d o net make the same
use o f them n o w that t h e y cic some tine ago. T h a t m a y

mean that the form o f the report, a s Governor Strong
suggested, m a y need revision.


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250
We have thought h e r e also that t h e budgets w h i c h
the Federal reserve benks h a v e p u t into u s e i n recent
periods o f ene t o five years have b e e n extremely benefietai.
Governor Norris. Y e s .
Mr. Smead. I

know thet officials i n a number o f

banks have t o l d m e that since putting t h e budget t n t o
use t h e y d i d n e t r e a l l y h a v e m u c h u s e f o r i t b e c a u s e

they feel that t h e y have a l l t h e control o v e r their e x penses t h a t t h e y could reasonably get, b u t that after
they p u t i t i n t o u s e a n d w e r e o p e r a t i n g

i t for a

while,

they found that t h e cepartment managers w e r e taking a n
entirely different attitude toward t h e costs o f their d e partment, a n d they were having very valuable results.
I persenally would hesitate v e r y much t o see t h e
banks d o away with Form E entirely. I
it i s quite likely that a

feel myself that

substantial revision might b e

made,

The Chairman,

H o w would y o u like t o have t h e Con-

ference pass a resolution requesting you and Mr. Rounds-Mr. Rounds w a s with y o u i n this matter, wasn't h e ?
Mr. S m e a c .

Yes.


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Federal Reserve Bank of St. Louis

251
The Chairman.

T o ask y e u a n d Mr.Rounds t o take

it u p w i t h t h e B o a r d t s c o m m i t t e e a n d s e e i f w e cannot
have a

pretty t h o r o u g h r e v i s i o n t h a t w o u l d n o t a t t e m p t

to change a l l t h e practices

i n the reserve hanks, b u t

eliminate the things where comparisons cannot well b e
made, a n d just take total figures f o r comparison a n d reduce t h e c o s t o f t h e w o r k i n v o l v e d

i n making

u p the

Form E? I n other words, retain what i s good and useful?
Mp. Smead. Y e s ; a n d I might make this suggestion,

Governor Strong, that you would not lay down too much o f
a straight-jacket with respect t o the matter, b u t i t
would probably b e a good idea for you t o ask the committee
to report t o the Governors! Conference a t the nextmeeting,

s o t h a t y o u w o u l d h a v e a n o p p o r t u n i t y t o pass u p o n

the work that t h e committee might do, a n d give t h e committee f u l l f r e e d o m t a m a k e s u c h s u g g e s t i o n s

a s occurred

to them, a n d I think also i n that connection i t might
be a good idea that y o u should have some resolutions t o
refer t o t h e committee.

The Chairman.

E v e r y bank n o w has a budget system

of s o m e kind, h a s n ' t i t ?
Governor Norris. Y e s , s i r , I

think so.


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252
Governor Seay.

M r . Chairman, t h e r e recently oc-

c u r r e d Ithink i n Chicago a

conference between t h e oper-

ating men o f the Federal reserve banks with tir. James,
upon t h e very subject, d i d there not?
Mr. Smead.

W h e n that conference w a s ¢alled t h e

functional expense reports were not specially o n the pro«
gram, b u t t h e y w e r e d i s c u s s e d t h e r e ,

a n d a t that confer-

ence there was some doubt a s t o the value o f the reports
as made u p 4 n their present form.

S o m e o f the members

of t h e c o m m i t t e e t h o u g h t c h a t i t w a s p r e t t y n e a r t i m e t o

discontinue them, others thought t h a t t h e y should b e
continued a s they are, a n d others t h a t t h e y could b e revisec properly; b u t t h e final result w a s that w e wrote
a report t h a t w e should n o t change t h e m just a t this
time, a n d I think that t h e members o f that committee
feel that within a reasonable time i n the future that
would h a v e t o b e t a k e n u p a n d i f p o s s i b l e a

Governor Fancher.

r e v i s i o n made.

A t that meeting h a d all o f the

banks g o t t h e budget system installed?
Mr. Smead. Yes.
Governor Fancher. I

got i t i n mind that perhaps

there were still t w o o r three banks t h a t h a d not g o t t h e


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Federal Reserve Bank of St. Louis

budget system installed.
Mir. Smead,

Well, I

think there were t w o o r three

that m i g h t n o t h a v e h a d t h e b u d g e t w o r k i n g i n a d e s t r a -

ble menner, b u t t h e y were operating under some f o r m o f
budget.

M o s t o f the banks I

think have a

very gaocd forn,

and t h e o p e r a t i n g d e p a r t m e n t s h a v e b e e n t a k i n g a

very d e -

cided interest i n it, a n d a s a result o f i t have achieved
some very desirable results.
Governor Talley. M r . Chairman,
referred to, I

a s budgets h a v e been

would like t o s a y that a s a matter o f fact

in our bank w e base o u r budget u p o n t h e results t h a t w e
obtain f r o m these reports, a n d that budget i s the l i d
to the box, instead o f the botton. I

had i n mind--there

is a motien before t h e Conference already--but I
mind offering a

substitute, b u t I

had i n

think this suggestion

which t h e C h a i r m a n h a s j u s t m a d e i s a l l right,

b u t that

we defer a n y action o n this until a t least t h e next Conference, a n d that i n the meantime w e ask the Beard t o ask
its examiners t o 3ee i f each bank i s following t h e manual
and m a k i n g u p t h e schedules. I

think t h a t i s w h e r e t h e

difficulty lies.
Governor Norris, I

was about t o ask a question along

254
thet line, Mr. Smead. I

presume t h e t y o u accept these r e -

ports e s t h e y sre made b y the banks. This happens t o b e a
cese s u c h 9 8 m y eye falls o n a t this minute, where t h e cost
per unit o n Government coupons i s .174 i n Dslles a n d .514
et ftlantea. “couldn't i t b e possible f o r y o u t o a s k Dalles
whether t h e y a r e sure that everything hes been included
in thet i t e m thet ought t o b e included, a n d elso t o a s k
ftlente w h e t h e r t h e y heave n o t i n c l u d e d s o m e t h i n g t h e t o u g h t
to h a v e g o n e t o s o m e o t h e r f u n c t i o n ? I


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Federal Reserve Bank of St. Louis

went t o rercd this:

"In connection with Generel Books now the menual stetes t h a t t h e following work, n o matter where
done £#n the benk, shell b e charged t o Genersl Books
unit: First, generol a n d subsidlery ledger; second,
officers c h e c k register e n d paying t h e officers checks;
third, preperetion o f deily stoetements; four,

daily telegrems t o Feder] Reserve Board and Treasury
Depertment; f i v e , préeparrtion o f w e e k l y p r e s s s t a t e -

ments; six, deily trenscript o f United States Treasury
account; seven, capitel s t o c k applications issued e n d
surrendered; e i g h t , m e i n t e n a n c e a c c o u n t s w i t h b r e n c h e s

and checklug o f brench trinscript;

nine,

reports e n d statistics f o r the Federel Reserve


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Federal Reserve Bank of St. Louis

Board o r for their o w n use; ten, a l l other work
incident toa the maintenance o f the general books

at the Bank."
One o f the larger banks i n the System reports t h a t
they d o that work with 1.95 employees.

O f course,

i t is

manifest t h a t t h e y are n o t charging t o that function a l l
the things t h a t t h e manual says t h e y must.

The Chairman.

W e could not pesibly d o it.

Gevernor Norris. C a n ' t y o u take that u p with that

bank, and i f you cannot, what i s the use o f having a report o n the expense o f that function , f one bank yuts
three things i n i t and another b a n k puts fifteen o r twenty?

Mr. Smead. Y e s , that could not b e done.
take u p a l l o f t h o s e m a r k e d d i f f e r e n c e s

W e could

i n t h e report,

but

it is a very difficult thing t o d o that from this end,
because i f you write t o a bank about these things i t i s
pretty h a r d t e p u t t h e i n q u i r y

i n such way that will

get a satisfactory reply, because the banks think a t
the p r e s e n t t i m e t h e y a r e f o l l o w i n g t h a t manual,

The Chairman. I

do not think w e do.

W e could n o

more make u p a n expense account uncer that heading,that
would i n v o l v e c u t t i n g o u r d e p a r t s a l l up.


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256
Mr. S m e a d .

What I

mean b y t h a t i s t h a t t h e y a r e

following i t t o the best o f their ability, d o i n g their
work i n ten different places, a n d there i s a let o f allocating.
The Chairman.

Y e s , w u t t h e application o f the di-

vision o f e x p e n s e w o u l d b e m o r e t h a n i t i s w o r t h t o c o m pile t h a t i n f o r m a t i o n

Mr. Smead.

o n t h a t basis.

T h a t a l l goes t e show that i t may b e

advisable t o materially revise t h e report.
Governor Harding.

D o e s t h e manual s a y anything

abowt postage o n country b a n k checks?
Mr. Smead. T h e manual i s pretty clear o n that,
Governor Harding.
Governor Harding. W h a t does i t s a y about that?
Mr. Smead.

I f m y recollection i s correct,

of t h o s e u n i t s t h e p o s t a g e

item.

i s taken care o f a s a

I t is quite complicated. I

o n most
separate

know postage i s not

handledt
h
e seme w a y i n all o f the units o f the bank,
and h o w i t i s o n that proposition I
Governor Harding.
ual t o t h e l e t t e r

cannot recall.

I f w e were t o carry o u t t h e man.

i t would involve considerable expense

in putting u p all o f these different items.


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257
Mr.Smead.

O f course,

i f y o u keep a n accurate rec-

ord, t h e cost would b e prohibitave.

The Cheirman. D u r i n g the war the regulations o f
this d e p a r t m e n t r e q u i r e d t h e t w e s e n d a

duplicate b i l l

for all telegrams

i n one continuous sheet, a n d dupligates

of all telegrams,

s c a s t o check up.

W e sent a n e

bill t o Washington which was forty-six feet lone, and
three trunks w i t h copies o f the telegrams.

T h e y took a

year a n d a half t o check i t u p and for o n e company w e
were $40 over i n the payments, a n d f o r t h e other company
we were $20 under, a n d I suppose t h e Government spent

$20,000 and got $20 back fer “t.
In these items w h i c h y o u read, t a k e t h e report, t h e
reports

i n connection

w i t h t h e business

doing f o r a l l t h e r e s e r v e b a n k s

buying bills, a n d s o on.

that

w e are now

i n foreign matters,

i n

T h e y a r e a l l made b y mani-

folding machines, a n d o f covrse t h e y g o out from the
department t h a t h a n d l e s t h e m .
partment

i s carried w i t h a

T h e expense o f the de-

certain allowence o u t o f t h e

revenue f r o m t h e a t h e r r e s e r v e b a n k s ,
able a p p o r t i o n m e n t

a n d t o make a

suite

o f t h e cost o f veporting a n d passing

it b a c k t o t h e r e s e r v e b a n k s , w o u l d b e a

very n i c e p i e c e


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Federal Reserve Bank of St. Louis

£o3
of cost accounting, a n d w e just have t o ignore these
things:
.
roo

believe,

Ib e l l @ g o m e r - i n a

f a m s ?s u m

i n t h a t dase.
’

i n your Cevartment, M r . Harrison. I

“fF

just have

a feeling that i f those things w e r e eliminated f r o m the
report a n d m a n y o f t h e i t e m s o f t h e r e p o r t a r e s t u d i e d

with a view t o getting a

calculation c f tne total costs

of some o f the departments where t h e departments a r e
thoroughly uniform, t h e n y o u could g e t a comparison o f
the number o f clerks empleyed a n d t h e number o f items
handled that would give a

rough check, without imposing

all o f this work and expense o n us,
Governor Fancher. T h e r e a r e three o r reur operating
departments

o f t h e banks t h a t y o u should m a k e v e r y favor-

able c o m p a r i s o n s o f , a n d t h a t i s i n y o u r c h e c k c o l l e c t fons a n d p a r t i c u l a r l y i t n your c u r r e n c y operations.

The Chairman.

T h e surrency works o u t mathematically,

put t a k e t h e c o u n t r y checks.

Governor Fancher. J

think there éan bé singled

out three o r four o r five o f the important functions o n
which t h e r e o u g h t t o b e a

basis

o f comparison,

and

then abandon a l l o f thise other wo:-k that i s done a n d
information w h i c h i s o f n o v a l u e a n d o n w h i c h t h e r e i s


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259
no basis o f comparison.

A

s G o v e r n o r B a i l e y says,

he has singled o u t certain things t h a t h e i s interested
in a s a

basis o f c o m p a r i s o n w i t h s o m e o t h e r banks.

The Chairman. H e r e i s one bank handling unbroken
packages o f checks, where w e count a

package a s rcoally

containing 750 o r 1000 items, a n d another bank will
weigh that a n d s a y there a r e 2,000 items i n it.
Governor Fancher. A b s o l u t e l y .

B u t i f y o u have

no basis of compiling the information, what value t s it?
Governor Norris h a s calculated that i t 1 s costing f r a m

$40,COO to 850,000 ta prepare this information which
is hot comparable.

I f that i s true, a n d i t probably is,

how much c a n b e eliminated f r o m that which i s o f value
and that which i s o f n o value?
Mr. Smead. I

would like t o s a y i n connection with

that cost, I have pérsonally asked a number o f banks how
much this report was costing them, including your bank,
Governor Strong, a n d i t was almost always t h e answer,

"Probably very little." T y e y did it along with some
other work that they would d o a n y way, a n d i f there i s
ah additional cost i t i s s o small that i t i s pretty
hard t o i r o n i t out.

T h a t m a y depend very largely o n


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Federal Reserve Bank of St. Louis

260

how a

given bank i s doing t h e work.

S o m e bank might

do the work i n such a way a s t o cost t h e m several thousand dollars.

O t h e r banks, l i k e N e w York, f o r instance,

{it would n o t c o s t b u t v e r y little. I

have n o t t h e

slightest i d e a o f what t h e System cost is, b u t i f i t

4scosting $50,000 a year i t is an item that is well
worth while looking into t o see i f we cannot cut down the
cost.
Governor Norris.

T

o the best o f our ability w e

have been following and observing the manual.

I t ap-

pears t h a t a t least t w o banks here a s t o certain things
at least have b e e n attempting t o follow t h e manual.
course, f
i w e threw t h e manual aside,
our costs, I

w e could reduce

suppose, q u i t e materially.

cost depends a

o f

S

o that t h e

good deal o n whether y o u are observing

the manual and doing all o f this cost accounting, o r
whether y o u are just ignoring t h e manual.
Mr. Smead. A n o t h e r thing,

i t depends v e r y largely

on how closely a bank's organization corresponds w i t h t h e
set-up o f f u n c t i o n a l e x p e n s e reports. I

understand

in

Governor Fanchev's bank that i t dees, consequently the
cost i n his bank would b e very, very slight, whereas


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Federal Reserve Bank of St. Louis

261

in another b a n k i t i s quite likely that t h e cost would
be very great.
Governor Talley.

I s there anything i n this thought,

to let the banksprepare t h e facts o r material f o r this
report, v e r y largely i n accordance w i t h their o w n organization, a n d then l e t y o u compile i t here? I
you a n example o f what I

will give

mean there. F o r instance, t h e

general books items, a s described iin the manual, a r e not
anything like o u r general books, because a l l o f that work

is not done i n that department, b u t now i f we could get
up our costs based upon what o u r general bocks department
is a s i t exists, t h e n o f course, a s applying t o our bank,

that would b e general books expense. T h e n aren't w e
going a b o u t i t p e s s i b l y t h e w r o n g w a y ? c o u l d n ' t

w e give

the i n f o r m a t i o n t o y o u h e r e a n d l e t i t b e c o m p i l e d h e r e ?

Mr. Smead.

W e here a r e very well aware o f just

what you say is very, very true, and that i n itself is
one reason why w e are pretty strong for the budget. When
you have a budget i n your bank you put that o n the line
at which your bank i s organized,
over t h e p a r t i c u l a r e x p e n s e

s o you c a n have control

i n mind, b u t w h e n y o u f a k e

the function expense report and you throw costs o f oper-


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Federal Reserve Bank of St. Louis

202
ations t h a t a r e c a r r i e d

ent units,
check.

c n under f o u r o r five differ-

i t i s impossible t o get a very satisfactory

T h e banks w o r k u p their o w n orzanization, a n d

having t h e Board heve a t Washington t r y t o put i t tozéther i n such a

way that anything o f a comparable nature

between banks would b e the result, would b e I think o u t
of the question.
to atterpt a

W e think i t would b e rather unwise

thing like that, because w e certainly can-

not p u t i t together a s the banks themselves would.
The Chairman. Gentlemen, I

have guaranteed a

number

of y o u t h a t w e w o u l d c o m p l e t e t h e p r e g r a m t h i s afternoon,

and this i s a kind o f a thing that w e could discuss i n
detail a n d c o u l d n e v e r settle.

do it.

T h e question

i s h o w toa

O n e way i s t o recommend the banks doing i t and

another i s t o revise i t and then again t o suggest h o w
it should b e revised. I
Governor Norris.

do not mean t h e actails.
W e have stated t o Mr. Smead

the thoughts t h e t a r e running i n our-minds a n d t h e dif-

ficulties that have led t o the introduction o f this
topic i n t o this Conference's program, a n d i f h e has
any suggestion t o make a s t o what would h e the best
way o f getting a t a further standardizaticn,
in}

i f possible,


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Federal Reserve Bank of St. Louis

265
of these renorts,

o r the cutting o u t o f such parts a s

cannot b e standardized, I
the suggestion. I

would b e very glad t o have

imagine w e would a l l b e glad t o

adopt a n y r e s o l u t i o n

t o t h a t effect.

The Chairman. T h e proposal,
was t o pass a

a s I understand it,

resolution indicating that t h e adoption

of the budget p l a n b y every reserve b a n k h a d n o w i n a
measure accomplished t h e results t h a t were sought f o r
by Schedule E , e n d that t h e time h a d arrived t o endeavor
to effect a

revision o f the method o f reporting Schedule E

that w o u l d b e m o r e e c o n o m i c a l a n d r e q u i r e l e s s w o r k a n d

simplify it, a n d that w e would request Mr. Smead a n d
Mr. R o u n d s

t o make a

s t u d y o f it, I

suppose

i n con-

nection with t h e Board's committee t h a t has charge o f
this, s o that before t h e next Conference w e could have

a recommendacion o f e plan.

I s that about what covers

the ground?
Governor Nornis. T h a t i s perfectly satisfactory t o

me, and i f you will just put that i n the form o f a motion
i will withdraw t h e motion that I
The Chairman. I

have previously made,

will g e t Mr. MNarrisen t o d o the

putting o f the form, a n d I will p u t t h e motion.

What


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Federal Reserve Bank of St. Louis

264
is your pleasure, gentlemen?

D o e s anybody want t o

second t h e motion?
Governor Fancher. I
The Chairman.

second that motion.

I s there a n y further discussion?

(The motion was put and carried.)
VI. Supplementary Topies.
B. Proposed revision o f Regulation D
dealing with reserves o f member banks..
The Chairman.

W e have t h e revised drafts o f regu-

lations and one i s headed "Collection o f maturing notes
and bills."
cS%

*

=

The Cheirman.

awe t

i t+

*

A f t e r d i s c u s s i o n o f f t h e record,

It was agreed that t h e following motion should b e submitted t o a

vote:

"Resolved, t o recommend t o the Federal
Reserve B o a r d t h a t n o r e g u l a t i o n

b e issued cover-

ing the collection o f non-cash ftems.

"Further Resolved, that the questions of (a
e uniform circular and (b) limitations upon the *"-:
character o f the items t o b e handled,

b e referred t o

the Standirg C o m m i t t e e n
o Collections f o r study a n d
recommendation

t o t h e n e x t Conference.


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265

"Further Resolved, that without waiting for
such repert, t h a t 7 % b e the policy o f the System
-to gradually discontinue t h e handling o f drafts
with bonds a n d stocks attached.

"Further Resolved, that i t is the sense o f
the Conference t h a t n o Federal reserve b a n k should
be e x p e c t e d t o collect n o n - c a s h i t e m s p a y a b l e

at

points where adequate a n d satisfactory facilities

do not exist.”
Governor Fancher. I

move t h e a d o p t i o n o f t h e f i r s t

separate resolution.
Governor Talley. I
The Chairman.

second it.

T h e first separate resolution

i s as

follows:

"Resolved,

t o recommend t o the Federal R e -

serve Board that n o reguiation b e issued covering
the c o l l e c t i o n

s

"

n

o f n o n - c a s h items.

v

(The motion was put and carried, Governor Seay
voving "No.")
The Chairman.

T h e second resolution i s a s follows:

"Fuither Resolved, that the questions o f (a)
a uniform circular, a n d (b) limitations u p o n the


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266

character o f the items t o b e handled,

b e refer-

red t o the Standing Committee o n Collections f o r

study and recommendation t o the next Conference.”
Governor Geery. I
Governor Seay. I

offer that.
second it.

{The motion was put and carried.)
Tho Chairman.

A n d the third one:

"Further Resolved, that without waiting for
such report, t h a t i t b e the policy o f the System
to gradually discontinue t h e handiing o f dra?ts

with bonds and stocks attached."
Governor Wellbcrn. I
Governor Bailey. I

move t h e adoption o f that.

second it.

(The motion was put and carried.)
The Ghairman.

A n d t h e next one:

"Further Resolved,

t h a t i t i s the sense o f the

gonference t h a t n o F e d e r a l r e s e r v e b a n k s h o u l d b e

expected t o collect non-cash items payable a t
points where adequate a n d satisfactory facilities d o

not exist."
Gevernor Geery. I
Governor F a n c h e r . I

make that motion.
second it.


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Federal Reserve Bank of St. Louis

Governor Bailey. I

second it.

(The metion was put and carried.)
The Chairmen. N o w w e come t o Regulation D .
Mr. Harrison.

T h i s regulation t s i n precisely t h e

form that was submittec t o the O p e n Market Investment

Committee, when five members o f the Board and I think
five members o f the committee a n d t w o other members o f

the Governors were present, a n d i t was agreed t o i n form
by everybody present i n that meeting.
The Chairman. W h a t this proposes i s that i n those
cities where there i s a reserve b a n k o r a branch, t h e ad-

justment shall be twice a week, and otherwise I believe
it is all left unchanged, isn't it?
Vr.Harrison. Yes. T h e y decided t o eliminate a l l that

proposal t o define time deposits, feeling that 1 t was
quite difficult t o de anything that would satisfy everybody under t h e present terms o f the law.
Governor McDougal. I

think t h i s r e s o l u t i o n s h o u l d

be considered very carefully.
The Chairman.

W h e n would y o u like t o consider i t ?

Governor McDougal.

I n the tantative draft which was

approved by the Board defining "savings" there was one


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268
provision that I
that d e p o s i t s

think was a

very wise o n e a n d that was

o f o n e b a n k i n another s h a i l n o t b e i n a n y

case considered a savings account.
protection, I

T h a t would give

think, against s o m e o f the abuses t h a t

have crept in. I

do not k n o w whether t h a t would f i t

Boston's c a s e i n some way, b u t I think that ought t o
stay in, a n d i t ought t o g o further a n d state that deposits o f banks a n d corporations shall n o t b e includeg
as savings accounts, because there i s a great tendency
on the part o f the banks t o solicit business o n the
strength o f issuing savings pass books against deposits
o r corporations,

made b y banks

w h i c h i n reality a r e paya-

ble o n demand.
fhe Chairman.

T h e r e a r e really f a u r points

i n connect-

40on with this n e w regulation, Governer McDougal, w h i c h
are possible changes o r suggestions t h a t require consideration. I

will e n u m e r a t e t h e m ,

if I

may.

O n e i s the

change t o the semi-weekly reserve report i n cities where
there a r e reserve banks o r branches.

T h e second i s the

adoption o f a scheme o f penalties f o r deficient reserves
by 4 progressive rate, w h i c h may, however,

b e waived i n

individual cases upon application to the Federal Reserve


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269
Board.

T h e third i s a provision f o r giving security

for t h e deposit o f trust funds, w i t h which Governor
Norris i s quite familiar.

W h e r e a bank which exercis-

es trust powers makes ceposit o f funds i n some other
bank, I

believe this regulation proposes t h a t t h e de-

positary b a n k gives t h e depositing b a n k security f o r
the deposit.

T h e fourth i s the question o f definition

of time a n d s a v i n g f
o deposits, r a i s e d b y Governor
Me Dougal.

I would like t o sey that I believe w e are all
agreed u p o n the semi-weekly arrangement o f adjusting
reserves, a n d i f you are ready t c vote o n that, w i l l
someone make t h e motion?

Governor Wellborn, I
The Chairman.

make that motion.

I s that seconded?

Governor Fancher. I

second it.

(The motion was put and carried.)
The Chairman.

T h e second point i s this progress ~

ive penalty, a n d I would like t o state I

think that i s

a very great mistake t o have any progressive penalty i n
any regulatior o f the Federal Reserve Board, a n d I believe i t will come back t o haunt t h e Board, because y o u


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Federal Reserve Bank of St. Louis

270
will f i n d t h a t e v e r y f a i l i n g m e m n e r b a n k b e f o r e i t

fails will subject itself t o a progressive penalty w h i c h
may g o u p t o 1 0 per cent, o r something l i k e that, a n d
then there will b e a howl.
Governor Harding. I

move that w e advise t h e Board

against it.
Governor Fancher. Don't t h e y cover that b y a waiver
provision a t the request o f the Federal Reserve Board?
The Chairman, T h e n w h y put in?
Governor McDougal.

T h e provision f o r a n accumulated

penalty, M r . Chairman, h a s been i n the regulation a l l
along.
Mr, Fancher. A b s o l u t e l y .

Governor McDougal.

Y o u h a v e i t now.

W e have lost 1 5 0 member banks,

and J think w e have never h a d a n y come-back that I
Governor Bailey. I

know of.

was wondering w h y that was p u t

in there.
Governor McDougal.

This i s a

re-graft

o f t h e regu-

lations.

Governor Harding. T h e y have a
the Federal Reserve Agent,
to notify t h e directcrs.

provision requiring

i n case o f a deficient reserve,


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Federal Reserve Bank of St. Louis

The Chairman.

T h a t ought t o b e enough.

Governor Seay.

D o I

understand t h a t y o u a r e o b -

jecting t o t h e p r o g r e s s i v e p e n a l t y u p t o 1 0 p e r c e n t ?
The Chairman.
the previous o n e ,

I t i s mandatory h e r e a n d optional

in

H e r e y o u have g o t t o impose i t , u n -

less y o u g o t h r o u g h t h e p r o c e d u r e

o f reporting

i t t o the

Federal Reserve Board a n d having i t waived.
Governor Norris.

W e have always treated t h e prev-

lous regulation a s mandatory, a n d have never h a d a kick.
Governor Fancher.
Governor Seay.

S o have we,

S o have we, a n d w e have never h a d a

kick,
Governor Talley.

W e have always considered i t a s

mandatory perhaps, because w e approved o f it.

W e have

assessed t h e penalties a n d collected them. I

do not

say that w e have done s o without a

Governor Wellborn.

complaint.

T h e penalty i s not s o great

after all, except that i t is i n excess o f the regular
rate. I

a m opposed t o a

The Chairman,

progressive r a t s , I

think.

W e l l , w e have discussed it, and I

think w e unders*and about it. Suppose w e vote o n it.
Governor Bailey.

D o e s that include that w e will


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Federal Reserve Bank of St. Louis

have t o come t o the Board t o get a rebate?
The Chairman.

Yes.

Governor Bailey. I

a m against it.

Governor Harding. I

offered a resolution that w e

advise t h e Board n o t t o incorporate it.
Governor F a n c h e r .

Y o u make i t permissible rather

than m a n d a t o r y ?

Governor Harding. Yes, permissive rather t h a n mandatory.

Governor Bailey. L e t i t stay just a s i t f2.
The Chairman.

A r e y o u ready f o r t h e question?

The

motion { s t o a d v i s e t h e B o a r d t h e t i t i s t h e s e n s e o f t h e

Conference that t h e penalty f o r defecient reserves
should n o t b e mandatory, b u t optional,

a s a t present.

Is that seconded?
Governor Bailey. I

second i t .

(The motion was p u t a n d carried.)
The Chairman.

T h e third question relates

t o the

giving o f security f o r t h e deposit o f trust funds. U n d e r
the p r e s e n t r e g u l a t i o n ,

a s y o u a r e aware, a

exercises trust powers--that i s , a

Governor Seay (interposing).

member b a n k

member national bank--

D o you intend b y that


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Federal Reserve Bank of St. Louis

273
resolution t o eliminate t h e waiver o f 4 penalty f r o m
this, Mr.Chairman?
The Chairman.

W

e intended

b y that resolutian

ta

put i t just back where i + i s now.
Governor Seay. T h a t would eliminate t h e waiver penalty.

The Chairman.

T h e Federal Reserve Board under this

regulation proposes t o make t h e progressive penalty mandatory o n us, t h e Board only reserving t h e right t o
waive i t .

Governor Seay. Tyat would eliminate this provision
in here, I

take 1 ?

The Chairman.

Yes.

G o v e r n o r Norris,

a r e y o u pre-

pared t o speak o n this subject o f giving security f o r
trust deposits?

Governor Norris. I

have been studying the regulae

tion o n that, a n d s o f a r a s I

out. I

can s e e that h a s b e e n thrown

understood that t h e L a w Committee o f the Board

was o f the opinior that they had n o authority t o impose
such a

regulation a s that, a n d t h e l a t e s t n e w s t h a t I

have h e a r d o n i + I

discarded. I

think w a s t h a t i t h a d p r o b a b l y b e e n

cannot f i n d i t i n here.

T h e provision


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Federal Reserve Bank of St. Louis

274
of Section TET~A, 2 s given o n page 4

o f X-4988, r e -

fers o n l y t o reserves against t h e trust funn. T h e r e
is nothing s a i d there aLout security a t all, a n d then

in Mr. Wyatt's memorandum o f August 15th, XK--4915, the
only change that h e suggests i n that is, t n order t o
make t h e language c f the section conform more nearly t o
that o f portions o f the regulations,

h e recommends

that the word “carry” be substituted for "maintain."
I would like t o b e sure that that its corrected o n the
paper b e f o r e s a y i n g t h e t vorovision f o r s e c u r i t y h e s b e e n

elimineted.
The Chairman.

W e u l d v o u care t o invite Governor

Young t o j o i n u s t e discuss t h i s r e g u l a t i o n ?

Governor Norris. I

would b e very glad to, a r I

think perhaps i f Mr. Hamlin i s here, h e i s more familiar

with it.
The Chairman- I

do not think w e can invite Gov-

ernor Hamlin without inviting Governor Young.
Gevernor Norrts.

O f course,

w e sheuld b e glad t o

have G o v e r n o r Y o u n g .

The Chairmun. i

mean t o s a y that, i f w e are going

to confer with a representative o f the Foard, w e ought

to confer with the head o f the Board, i t seems t o me.
Governor Norris.

G o v e r n o r Fencher calls m y ate

tention t o the fact that t h e security o f uninvested

trust funds i s i n regulation (F) end not i n this section, a n d that h a s n o t been referred to.

T h i s i s simply

a question o f the reserves.

The Che irman.

I f you please, w e will wait until

Governer Young comes in, t o continue the discussion o f

Regulation (D), and I

wovld .like t o take u p now the re-

port o f the Subcommittee o f the General Committee o n
Penkers Acceptances::

H a s that b e e n distributed?

Mf. Harrison. Y e s , sir.
VI. S u p p l e m e n t a r y Topics.
A. R e p o r t o f s u b - c o m m i t t e e
Pankers f a c s p t a n c e s .

The Chairmen.

T h i s i s a report,

o n

a s v o u know, which

was made b y the Special Committee o f officers o f five o f
the banks, I think, which met i n New York, and hadéas..
conference w i t h t h e vice-presidents a n d pertners o f

the nrincipal accepting banks and firms, reviewed all
of the rersulations and ‘pulinrs o f the Federel Reserve
Poard releting t o the scceptance practice, a n d after a

good déel of study have submitted a report, o f which
you h a v e @


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Federal Reserve Bank of St. Louis

copy.

The r e p o r t o f t h e G e n e r r l ‘ c c e p t a n c e C o m m i t t e e a n d t h e

Sub Committee o f the General Committee o n Benkers Scceptance


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Federal Reserve Bank of St. Louis

is a s follows:

"October 28, 1927.
"Report b c the Governors Conference o f November 2,
1927, b y the Cheirmen o f the General ‘eceptence C o m mittee s n d the Sub-Committee o f the Generel ‘cceptance
Committee.

"Since the last Gonference o f Governors the only
matter thet has b e e n referred t o either o f these committees w a s t h e juestion o f whet impediments,

i f eny,

existed thet restricted t h e free competition O o f
fmericen doller scceptence credit w i t h sterling o r
other foreign currency credits issued b y foreign
bankers i n connection with foreign trade.

T h e Fed-

erol Reserve B o e r d requested consideretion o n d reeommendetion

b y o n e o f these c o m m i t t c e s

i f possible

piior t o the presence Conference.

"*ecordingiy the matter was considered b y the
Sub-Committee o n October 21, 1927° a n d recommendation
in t h i s r e g o r d m s d e t o t h e F e d e r a l R e s e r v e B o a r d .

Copy o f the report o f the Sub-Committee t o the Federal


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Federal Reserve Bank of St. Louis

275-b
Reserve Boerd, which i s self-explenrtory,

i s at-

teched hereto a s supplementing e n d completing this
report

o f the Sub-Committee

t o this Conference.

"Respectfully submitted,
"E. R. Kenzel,
"Cheirmen."”
"Report o f the Sub-Committee o f the Generel /eceptence Committees t o the Federel Reserve B o e r d October
fig. 1927.

"The Sub-Committee o f the Genersl /eceptenc? Com-

mittee held a meeting i n New York on October 21, a t
which t h e following were present: M e s s r s . Zurlinden,
Peddock, M c K a y e n d “yett, M ur. Kenzel cheirman, e n d
Mr .O'Here, s e c r e t e r y .

"Consideretion wes given t o * proposel t o recommend
to t h e F e d e r s l R e s e r v e B o a r d c e r t a i n m o d i f i c a t i o n s

of

its existing rulings w i t h reference t o sceceptsnces
growing o u t o f the importation a n d exportstion o f
foods w h i c h w i l l m a k e i t p o s s i b l e f o r f m e r i c e n b e n k s

to recespt bills drewn u p o n t h e m f o r the purpose o f
finencing s u c h t r a n s e c t i o n s w h e r e

i t i s necessrry

for such bills t o b e drawn efter t h e goods have


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Federal Reserve Bank of St. Louis

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recched their aestinetion,

i n order t o conform t o

uguel c o m m e r c i a l a n d -credit practices.

"tfter full discussion o f the subject a n d consideration o f a stetement o f facts releted b y the Cheirman
substentially e s expressed i n the accompenying memorandum i t was unenimously voted b y the Committee t o
recommend

t o the Bosrd e s follows:

"hat t h e Board revoke its previous rulings t o the
effect thet e

bill cannot b e eligible for. acceptance

e member bank o r for rediscount o r purchese b y 4
Federal reserve b a n k 9 s s bill growing o u t o f the im-~
portetion o r exportstion o f goods i t i s i s accepted after
the goods have reeched their destinetion, e n d rule i n
lieu thereof;
"Met benkers sceceptance m a y properly b e considered
es growing o u t o f transections involving t h e importation o r e x p o r t e t i o n

o f soods w h e n g i v e n f o r t h e p u r -

pose o f f i n e n c i n g t h e s e l e e n d d i s t r i b u t i o n

o n usual

credit terms o f imported o r exported goods i n t o t h e
chennels o f trede, whether o r not t h e bills s r e secept-

ed efter the physicel importction o r exportetion has
been completed. "


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Federal Reserve Bank of St. Louis

275-d

"Menorandum o f Statement b y the Choirman o f the
Sub-Committee

o f the Genersl feceptence Committee

a meeting o f the Committee i n New York o n
October 21, 1927.
"The question o f the monner »nd extent t o which use
of ‘merican acceptance credit w a s hindered i n competition w i t h f o r e i e n c r e d i t

i n finencing foreign trade

was t h e subject o f inquiry recently mede b y the Fed.
erel Reserve B o a r d o f vour Chairman.
"On a visit t o “eshington lost week, y o u r Chairmen
exnlained t o Governor Young e n d t o the Federal Reserve

Bosrd that, sccording t o his observetions e n d from informetion gained f r o m interviews w i t h m a n y bankers *
from Englend, Hollend, Switzerland, Germeny, France
end Itely, t h e o n l y precticel obstacles l a y i n rulings
of t h e B o s r d w h i c h h e d t h e e f f e c t

o f prohibiting

bills f r o m being atcentsd s t all b y nationel banks o r

*8eligible b y other venks and benkers after the physLesl e x n o r t a t i o n

o r importation

o f goods w a s completed.

"He steted thet these foreign benkers hed told him
thet industrucy i n the industrisl counties o f the

Continent hed always had t o look t e foreign credit


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Federal Reserve Bank of St. Louis

275<e
for the pusrchese o f imported r a w materials a n d i n the
export

o f finished g o o d s ; t h a t d u e t o verious c o u s e s ,

Such c r e d i t w e s r e q u i r e d f o r l o n g e r p e r i o d s t h a n w e s

customsry i n the United States.

f m o n r the ceuses

nemed were leck of working cppitel i n the ‘mericen
sense, s l o w t r a n s p o r t a t i o n ,

c e okoatne o f river nev-

igation during the c o l d months, a n d t h e e c o n o n t i cm
i

precticobility o f industries closing down temporerily
or for longer periods,

a s i s frequently adiee i n the

United States without serious economic consequsntes.

The combined effect o f these conditions requires manufecturérs sersonelly t o corry row meterisls f o r six
months

o f o p e r s t i o n e n d they, s e c o r d i n g l y , r e q u i r e

eredit u p t o s i x months w i t h respect t o » considerable

portion o f their purcheses.
"The fact that banks o n the Continent = r e much more

closely identified with the industries t h e n i
s the
generel cese i n fmerica normally permittcdthem t o discount f r e e l y f o r t h e i r m i n u f e c t u r i n g c l i e n t s s n d e l s e

to procure f o r them from ebronad t h e additionel foreign

credit thet they required. Englend, Hollend, Switzerlend,

enil to some extent, France, were normelly the ereditor


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Federal Reserve Bank of St. Louis

275-f
countries o n d the first three continue e t the present time t o extend t h e kinds o f credits f o r the time
required t o the Continental industries; generslly
through the medium o f Continentel benks.

"It was expleined thet, owing t o the higher price
‘evel s t t h e p r e s e n t t i m e a s c o m p a r e d w i t h pre-war,
the v o l u m e o f domestic b i l l s
industrial s e c t i o n s

i n Germeny e n d other

o f the Continent represented e a

Physicel volume o f goods considerebly less, perheps
75 per cent o f the quentity o f goods, t h e n vould heve

been represonted b y e n equal emount o f bills pre-wer,
end that, sccordingly, t h e rise i n the price level re-

quired relstively greeter reccurse t o foreign credit
then before t h e wer.
"It wes explained thet b o t h before s n d since t h e w e r
it wes t h e prectice o f London benks e n d bankers t o ex-

tend commereiel scecentence credit for the benefit o f
Continental industry a n d trede freely a n d thet t h e re-

strictions i n the ‘mericen prectice h a d d o u b t l s caused
& preet d e e l o f f i n s n e i n e

t o g o t o London t h e t otherwise

would h e y e c o m e t o N e w Y o r k o n s c c o u n t

o f the sbility

uf fmericen t o crerte credit end the lower *merican
diseount r e t e s .


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"Me cutting o f seceptance commissions b y London
benks f o r Continentsl banks t o atbroct this k i n d o f
business

t o London wes a l s o referred

t o e s consti-

tuting 9 substantial competition b u t o n e which would
not b e s o serious i f ‘merican benks could give t h e
credits t h e t t h e Continental trade requires c n terms
otherwise e q u s l w i t h London.

"Since your Cheirmen advised the Roerd i n these respécts, h e hes confefred with a considersble number
of prominent N e w York benkers w h o creste t h e large
bulx o f fmerican scceptences t o inquire o f them what i n
their experience h a d prevented t h e m f r o m giving acceptence credits sbroad s u c h e s London bankers hebituslly
great,

o n d h e was informed

b y eech o f them thet t h e

rule segeinst accepting after goods h e d srrived i n the
country o f import e n d the rule egsinst permitting customers

t o redraw ofter goods h a d errived

{ n the country

of import were t h e o n l y t w o points u p o n which t h e y felt
their d i s e b i l i t y doperded.

"They felt that they would net wish t o extend credits
in Europe. f o r pureiy domestic purposes, expleining
thet b y thet t h e y meant t h e vurchsse o f goods o f domestic


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origin, t h e fabrication o f such goods a n d fits sale

for domestic consumption within a n y European country,
but thet t h e y did feel thet t h e y should b e permitted

to finance through ececeptance credits the sale within
Europeen c o u n t r i e s

o f goods o f o r i g i n f o r e i g n t o t h o s e

countries, and the fabrication and sale o f goods for
export.

M a n y o f them eited t h e familiar problem o f

American cotton which i s now sent g e largely t o European countries o n consignment b y fmerican shippers

snd i s sold t o Europesn spinners out o f warehouses i n
Europe. S p i n n e r s require credit o f ninety days o r more.
Under t h e p r e s e n t r u l e s , ¢émerican b a n k s c e n g i v e s u c h

credits where t h e cotton crosses a

frontier i n Euorpe,

that is, where i t is exported from one European country
to another, but they cannot give such credits i f the
cotton i s sold t o spinners located i n the same European
country i n which i t is stored pending sale. /

similer

negative position arises w i t h respect t o cotton which

is sold snd shipped from ‘merica o n terms that have become quite usuel, i.c., that a t the buyer's option h e
may p a y cash o n arrival o r give ninety days benkers
credit.

I t frequently heppens t h a t t h e cotton has a r -


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275-4
rived sand s o the nhysicsl export completed before t h e
buyer e l e c t s h o w h e s h a l l pey.

I f h e elects

t o give

ninety days bankers eredit t h e benker m a y not accept
the bill i f the cotton has arrived s t the foreign destination named i n the shipping documents.

\The American bankers consulted felt that the time
nes certainly arrived i n the development o f American
acceptence b u s i n e s s w h e n f m e r i g a n a c c e p t i n g b a n k e r s
should b e p e r m i t t e d t h e f r e e e x e r c i s e

o f their discre-

tion within t h e l a w a n d regulations a n d that, within
‘those limits, f u l l latitude should b e granted t h e m i n

the accommodstion o f business a s i t i s done i n foreign
countries.

T h e y stressed pertioularly t h e point t h a t

they regarded i t e s preferable t o give a

three months

credit with a renewel for a further period, i f i t were
found that a renewal were required e t the expiration o f
the original period, t h a n t o grant t h e eredit originally

fcr a period o f six months, a n d that i f the rule sgainst
eccepting « bill after t h e goods h a d arrived were
rescinded, t h e e n d sought would b e practically acgomplished without ©
bills.

specific ruling @ n fevor o f renewal

I t w a s p o i n t e d o u t t h a t f r o m t h e bankers!

point


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275-4

of view i t was prefersble t o b e able t o review
credits

a t more frequent intervals t h a n i s t h e c a s e

when credits u p t o s i x months e r e being insisted

upon b y the borrower a s a precaution against being
unable

t o redraw a t the e n d o f a

shorter p e r i o d

in

case o f need even f o r a small part o f the credit.


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{At this point Governor Young came ‘nto the
Conference R o o m . )

The Chairman. Governor Young, w e a r e struggling

with some regulations, a n d I will tell yeu what w e have
done t o date a n d then w e struck a snag a n d thought w e
had better have y o u in.

A resolution passed I think almost i f not quite
unanimously suggesting t o the Board that n o regulation
be i s s u e d g u s t n o w o n n o n - c a s h c o l l e c t i o n items.
have g c t t e n a l o n g a f c e r a

fashion f o r t e n years,

W e
and

we thought w e might struggle along a while longer, a s
there was some question abcut t h e position that i t
might leave t h e banks i n i f such a regulatien were issued.

T h a t i s the first resolution passed b y the Board.
There were three other resolutions passed, t h e

first referring t h e matter t o the Committee o n Non-Cash
Collections; a n d , s e c o n d ,

t h e enumeration

o f items

which i t was undesirable t o handle; t h e n a resolution
was passed accepting t h é sense o f the Conserence t h a t
it should b e cur policy gradually t o discontinue t h e
handling o f these stock a n d bond security drafts.

T h e


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volume i s increasing v e r y rapidly, a n d there i s a great
responsibility a b o u t i t , a n d w e h a v e j u s t g o t t o s t o p

it i n New York, t h e r e i s n e question abetit; a n d finally
we passed a

resolution that i t was t h e sense o f the

meeting that n o reserve b a n k would b e expected t o collect items o n points where there were n o satisfactory
collection facilities, a r d i t seems t h a t that general

expression giving the committee stx months t o work o n
it and report t o the next Conference,

i n the meantime

without a n y regulation and then graduaily cut down
and eliminate the security drafts.

W e are not asking

you t o express a n y v i e w a b o u t i t , b u t w e a r e j u s t r e -

porting informally o n what w e d i d o n that o n e subject.
Now, w e took u p the question o f regulation o n re-

serves, and we have just unanimously agreed that the
provision f o r semi«weekly reserve adjustments o f the
member b a n k s

branches,

i n cities w h e r e t h e r e a r e r e s e r v e b a n k s a n d

i s satisfactory t o everybody.

W e felt that

there w e r e t h r e e o t h e r i t e m s f o r conside:ation,

I find i s not i n this regulation. I

b u t one

did not realize it.

The one that i s i n Regulation F is the one requiring security f o r deposit f o r trust funds.

T h e other t w o items


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are
here i n this regulation are, first, t h e question o f

the definition o f time and savings deposits, e n d w e
wanted t o a s k y o u t o m a k e a n e x p l a n a t i o n

o f that, a n d

the third item i n this regulation o n reserves i s t h e
manner b y which there i s provided a

mandatory pro-

gressive penalty for deficient: reserves, with the exception that t h e Federal Reserve Board might waive t h e
penalty o n application f o r cause, a n d s o on.
We b e l i e v e t h a t t h a t i s a

mistake,

a n d that i t

would b e better t o have t h e penalty optional,

a s i t is

now, a n d not mandatory, j u s t t o avoid possibly getting
into a

jam o r a criticism a t this time, a n d that was

reported u n a n i m o u s l y a s o u r r e c o m m e n d a t i o n

t o t h e Board.

We pave come t o the subject o f the definition o f

time and savings depesits, and accepting i n principle
that the deposits o f banks could not b e construed a s

savings deposits, Governor McDougal suggested that that

should be extended td include corporations, and at that
peint I
needed a

fel that w e were getting i n t o deep water a n d
little b i t o f dtséudaion w i t h y o u a s t o how this

thing h a d developed.
Governor Young. I

cannot discuss t h a t particular


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279
part c f the regulations.

A s I recall, t h e regula-

tion was sent out limiting every savings account t o
$5,000, and innumerable suggestions, a n d limiting corperations cther t h a n religious o r charitable organizations. a n d all such ideas a s that.

T h e comments c a m e

in from all t h e Federal reserve banks o n that, a n d i t
was t h e conclusion o f Mr. Ylyatt a n d the Board that w e
might better eliminate a l l those provisions rather t h a n

to attempt t o discriminate, a n d what they have really
done i s t> go back t o the old regulation, that i s Just
about what * t amounts to, a n d they attempted t o cover
the California situation, a n d when t h e y got a l l through
it they found o u t that t h e y could n o t cover i t very
well,

a r d found o u t that there i s only o n e w a y y o u c a n

handle this.

T h e description o f savings accounts a n d

time deposits that is in that regulation now is as good
as anybody can describe it, i n our opinion.
Governor McDougal. M r . Wyatt's idea, Governor Young,
{3 that these cases c a n b e dealt w i t h b y a ruling, a n d
it 1 s better t o h e handled that w a y than i n a regulation.
In the tentative draft that w a s approved b y the Board,

there was one very good provision, I think, contained


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280
in that,

b y which deposits m a d e b y one bank i n another

could n o t b e under a n y conditions considered a s savings
acceunts, a n d I think that i s a very wise precautionary
measure

t o adopt,

a n d beyond t h a t I

had m a d e t h e s u g -

gestion here that deposits o f corporations cught t o b e
and could properly b e included i n this same category

as not being savings accounts from the standpoint o f
the question involved here, t h a t o f determining t h e reserve requirements, a n d I think i t would b e very much
more e f f e c t i v e a n d s a t i s f a c t o r y i f t h a t c o u l d b e c o v ered b y a

regulation, b e c a u s e t h e t e n d e n c y w h i c h w e s e e

in one o f our banks apparently 4 8 t o b e found i n other
districts too, whereby banks a r e encouraging t h e deposits
by banks a n d b y corporations a n d issuing i n this case a
special s a v i n g s b a n k check, u n d e r w h i c h t h e y m a y o r

they m a y not have t h e right t o take thirty daystnotice
or require thirty days! notice, but: with: vespect t o which
they p a y them without presentation o f the nass-book

excepting b y the bank itself, a n d making them i n fact
subject t o check, a n d they are checking accounts.
I would like t o see that safegaarded.

B y a ruling

it i s going t o b e very difficult t o handle, because y o u


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281
will have t o take i t u p with each bank a n d y o u will
have t o ‘send y o w examining officers o r detectives i n t o
the Dunk t o see whether i t i s being done o r not; whereas

if it is i n the regulations i t witl b e right t a r e
Governor Young.

S o far a s the deposits o f one bank

with another i s concerned,

m y reaction agrees w i t h yours;

fin s o f a r a s t h e c o r p o r a t i o n s a r e concerned,

t o cotrect

the abuse o f a few corporations, y o u would penalize m a n y
institutions

t h a t h a v e bona-fide transactions.

Northern

Michigan t s just filled with corporations savings accounts that have been there for ten, fifteen o r twenty
years.
Governor Seay. N o t commercial corporations?

Governor Youwhp. Yes.
Governor McDougal. Y o u would n o t penalize t h e m a t
all, b e c a u s e y o u c o u l d t a k e t h a t c l a s s o f deposits a n d

convert t h e m into time deposits instead o f savings.
they a r e t i m e deposits, t h a t c o u l d b e s o adjusted, I

If
am

sure.

Governor Yucung.
since I

I t is almost three o r four months

went over this whole matter, a n d i t i s not fresh

in m y mind. I

read t h e r e g u l a t i o n t h i s m o r n i n g a n d r e a d


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Me. Wyatt's Peport: I

think i t might b e t o the advant-

age o f the Conference t o Have Mr. Wyatt c o m e in--I think

I coud get him t o come in--because those things are all
fresh i n his mind, a n d h e has been wrestling w i t h then,
and h e c a n give y o u a better answer t o that t h a n I can.
Gevernor McDougal. I

think his answer i s pretty

well covered i n the memorandum which h e prepared.
idea i s that,

His

b y dealing with these questions b y a

ruling rather t h a n b y a regulation, probably t h e Board
is keeping o f f dangerous ground, f o r t h e reason that t h e
danger o f l a w s u i t s a n d t h i n g s

o f t h a t sort,

h e says,

are n o t s o great when y o u are dealing w i t h a ruling a s i t
would b e i f there should b e a blanket regulation.

H e

argues a t least along those lines.
Governor Young. I

a m sorry that a t the moment I

not give y o u a n y more information t h a n I have now.

can-

I t

is out o f m y mind a n d i t has been three o r four months
since I

have considered t h e problem.

Governor Geery. G o v e r n o r M e Dougal | o n page 2 under

section I I (d), 3 appears the following;
"Deposits which are permitted t o be withdrawn
by check o r otherwise, without the .ctual presen-

283
tation o f thé check book, certificate o r other
similar
form o f receipt whenever a

withdrawal i s made, shall n o t

be considered 'savings accounts! within t h e
meaning o f
this regulation,”

D o e s n ' t t h a t cover your point?

Governor McDougall. W e l l , there i s a question about
that, G o v e r n o r , b e c a u s e

i t i s contended

O n One side that

the pass book i s presented.
The Chairman. T h e case where t h e original pass
book
is lodged i n the bank a n d remains there, a n d a duplicate
is sént ous.

Governor Geery. I t says right here, "The retention
of the pass book, certificate o r other similar f o r m o f
re-

ceipt, o r a duplicate o f same, b y the bank and the presentatior o f same b y the bank t o itself i s not a n Tactual
presentation’ within t h e meaning o f this regulation."

Governor Young. M r . Wyatt i n his memorandum cuts
thet o u t .

Governor Strong, i f I uaderstand this correctly, the
new regiiation i s practically t h e same a s the o l d regulation,
with t h e e x c e p t i o n t h a t t h e r e i s a

mandatery provision f o r

penalty?


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The Chairman.

A n d t h e s e m i - w e e k l y plcvosition,


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284
Governor Young. Yes. T h o s e a r e t h e things t h a t a r e
really u p t o the Board. I

do not think i t i s advisable

to actempt t o change t h e regulation. I
on t h e p e n a l t y o n reserves. I

agree with y o u

think t h a t i s e x t r e m e l y

dangerous, f r o m long experience i n the Northwest.

Y o u

get a bank that i s slipping and you think that you can
help t h e institution out, a n d frequently y o u refuse t o
lend money because y o u want t o keep t h e m short i n reserve.
That i s one o f the strongest weapons y o u have with a
weak bank.
goes down, &

T h e bank cennot weather t h e storm a n d finally
receiver comes in, a n d the steckholders,

through a n investigation a n d what-not, f i n d that under
those unusual conditions t h e Federal Reserve Board penalizes that institution 1 0 per cent.

I t i s a n argument

that you cannot justify, a n d i t will cause a lot o f
trouble.

I f a good bank slips i n its reserve y o u are

always i n a position t o deal w i t h that institution without a progressive penalty. I

had rather s e e i t left out,

and I a n g l a d t e krow that that i s a majority view.
Governor KeLDougal.
been--ontional?
have n o w .

J t i s t o b e left just a s i t has

S o m e banks have epplied i t and some


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285

The Chairman. That answers the two matters you
submitted t o me, except t h e question o f giving security
for trust deposits.
Governor Young.

A l l . the banks a r e i n agreement

about that, with the exception o f Cleveland and Philadelphia, a n d I do not think that their Governors wanted t a
bother with that. M a y b e w e can straighten i t out.
The Chairman. Then w e will pass that.

T h a t leaves

only the regulation about liberalizing the rules o n ac~
coptances.You have j u s t read t h e report, a n d w e are just
about ready t o vote o n it. A r e y o u ready t o take some

action o n the report o f the committee?

T h e report has

been distributed.
Governor McDougal. I

Governor Fancher. I

move t h e a d o p t i o n o f t h e report.

second it.

(The motion was put and carried.)
The Chairman. Governor Young, w e passed a resolution
indicating t o the Board that w e thought t h a t a

meeting

of t h e c o u n s e l o f t h e f e s e r v e b a n k s w o u l d b e a

very desir-

able thing, a n d there i s just one topic left o n the
Governors!

program o f a

legal c h a r a c t e r w h i c h w e w o u l d

ordinarily leave t o that meeting i f i t 1 s t o b e held.


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286
Iam taking i t for granted that i t will have serious
consideration b y the Board, a n d I

a m going t o a s k this

Board t o refer Topic VI-C t o the meeting o f the counsel.
Is there a n y objection t o that?
Governor S e a y . T h a t i s t h e c o u r s e I
myself,

s o I

recommended

make t h e m o t i o n t h a t i t b e referred.

(Motion p u t a n d carried.)
The Chairman.

A t the meeting tomorrow morning,

Governor Young, w h a t would y o u like t o have u s deal with?
Governor Young.

T h e o p e n market topic here has al-~

ready b e e n d i s c u s s e d b e f o r e t h e Board.

T h e r e i s n o use

going a n y further about that.
The Ghairman.

I t has b e e n discussed w i t h this mect-

ing, a n d w e s u c g e s t e d t h a t i t w o u l d t a k e t h e u s u a l c o u r s e - -

the report was received ani discussed i n much detail,
and that i t now g o t o each bank for action b y the directors. I

mean, t h a t cannot b e finally approved here, b e -

cause a l l o f these proposajs a r e subject t o the action
of t h e b o a r d o f directors

o f e a c h bank.

Governor Young. " R e l a t i o n s w i t h foreign banks" h a s
already h e e n r e p o r t e d a n d d i s c u s s e d ?
The Chairman.

Yes.


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£87
Governor Y o u n g .

The Chairman.
uation.

W h a t w e r e your conclusions

o n ID?

W h y , i t i s a rather interesting sit-

W h e n a member b a n k submits a n application f o r

discount,

i t will submit a n item with the letter P indi-

cating that i t i s purchasing t h e paper, a n d S indicates
and that a statement i s o n file.

that i t has been discounted/

I f that i s a corporetion,

say for instance a milling company out there, with subsidiaries, t h e question arises a t once i f that i s a complete s t a t e m e n t w h e n t h e p a r e n t c o m p a n y f i l e s i t s s t a t e -

ment.

W h a t actually happens i s that w e decide,whether

that i s logicel o r not, b y looking u p our files t o see
whether there i s a statement o n file, a n d t o see whether
it conforms

t o t h e regulation,

t h e statement having b e e n

“furnished t o us b y a member bank, a n d we will assume
that t h e m e m b e r b a n k w h i c k b u y s t h a t p a p e r

i n the market

has got ‘ @ statement o n file which conforms t o the regulations.

I t may have the consolidated statement o r

it m a y h a v e t h e c o n s o l i d a t e d s t a t e m e n t a n d t h e s t a t e m e n t
of a l l o f t h e subsidiaries,

b u t when this paper comes in,

when i t i s offered t o us, w e are not going back a n d say,
"What iebha o f a

statement h a v e y o u ?

the regulations?"

D o e s i t comply w i t h

W e have got ore which complies with


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Federal Reserve Bank of St. Louis

268
the regulations, a n d w e got i t from a member bank, a n d
it seems t o m e that that meets t h e situation.
Governor McDougal. Governor Strong,
Then then. thet.

W

w e went fur-

e went t o the point w h e r e i t was

moved that complete statements b e filed with a l l t h e
depositary b a n k s w h i c h p u r c h a s e d c r e d i t loans.

Governor Geery. H e r e i s a copy o f the resolution
as passed (handing paper t o the Chairman).
The Chairman.

I f there i s nothing further, I

declare t h a t t h e C o n f e r e n c e

(Whereupon,

adjourned.)

o f Governors

will

i s adjourned,

a t 5 . 2 0 p.m., t h e C o n f e r e n c e

o f Governors


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