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418

A. meeting of the Board of Governors of the Federal Reserve
SYsten was held in Washington on Friday, April 15, 1938, at 10:30
a.

m

PRESENT:

Mr.
Mr.
Mr.
Mr.
Mr.
Mr.

Eccles, Chairman
Ransom, Vice Chairman
Szymczak
McKee
Davis
Draper

Mr. Morrill, Secretary
Mr. Bethea, Assistant Secretary
Mr. Carpenter, Assistant Secretary
Mr. Clayton, Assistant to the Chairman
Mr. Thurston, Special Assistant to the
Chairman
Mr. Wyatt, General Counsel
Mr. Goldenweiser, Director of the Division
of Research and Statistics
Mr. Snead, Chief of the Division of Bank
Operations
Mr. Dreibelbis, Assistant General Counsel
Mr. Vest, Assistant General Counsel
Reference was made to discussions which Chairman Eccles had
had with the President, conferences which. Messrs. Eccles and Ransom
had held with the
Secretary of the Treasury and others, and informal
scussions of the members of the Board of Governors with respect to
4cti°fl by the Board of Governors to reduce reserve requirements of member banks
as a part of a program to be adopted by the Government for
the en
couraganent of economic recovery. It was stated for the record
that

as the result of these discussions the members of the Board had

/agreed informally that Chairman Eccles should state to the President
that

the Board would be willing to reduce reserve requirements by




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4/15/38

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ePproximately 050,000,000, with the understanding that it would be a
Part of the program referred to above.

The program adopted by the

Administration was announced by the President in a message which was
sent to Congress on April 14, 1938.

A copy of the President's message

has been
placed in the Board's files.
At the request of the Board, Mr. Smead discussed the various
Percentages by
which reserve requirements of the different classes of
Member banks covering demand and time deposits might be reduced and it
was agreed to reduce the required reserves of central reserve and reserve city banks on demand deposits by the amount of the increase which
became effective on May 1, 1937, the required reserves of country banks
on demand deposits to 12 percent of such deposits, and the required
reserves of all
classes of banks on time deposits to 5 percent of such
dePosits.
Thereupon, Mr. Ransom moved that
the following supplement to Regulation
D be approved and adopted to became effective as of the opening of business on
April 16, 1938:
"SUPPLEMENT TO REGULATION D
"Effective as to each member bank at the opening of
business on April 16, 1938
"Reserves required to be maintained by member banks
with Federal Reserve banks
"Pursuant to the provisions of section 19 of the Federal Reserve Act and section 2(a) of its Regulation D, the
Board of Governors of the Federal Reserve System hereby




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4/15/38

r4.

"prescribes the following reserve balances which each member bank of the Federal Reserve System is required to maintain on deposit with the Federal Reserve bank of its district:
5 per cent of its time deposits plus-12 per cent of its net demand deposits if not
in a reserve or central reserve city;
17A- per cent of its net demand deposits if in
a reserve city, except that if located in an outlying district of a reserve city or in territory
added to such city by the extension of the city's
corporate limits such bank may, upon the affirmative vote of five members of the Board of Governors
of the Federal Reserve System, be permitted to
maintain 12 per cent reserves against its net demand deposits;
22-3/4 per cent of its net demand deposits
if located in a central reserve city, except that
if located in an outlying district of a central
reserve city or in territory added to such city
by the extension of the city's corporate limits,
such bank may, upon the affirmative vote of five
members of the Board of Governors of the Federal
Reserve System, be permitted to maintain 12 per
cent or l?c per cent reserves against its net
demand deposits.
"The supplements to Regulation D which have previously
been Issued are hereby revoked and superseded."
Mr. Ransom's motion was put by the
chair and carried unanimously.
There was presented a draft of a statement prepared by Mr.

Thurston for
release to the Dress with respect to the above action.




Certain changes were suggested in
the statement following which it was approved unanimously in the form set forth
below, with the understanding that it
would be released to the press this afternoon for publication in the morning newspapers of April 16 and that copies of
the revised supplement to Regulation D
and the press statement would be sent by
wire to all Federal reserve banks with a
request that copies of the supplement and
press statement be mailed to all member
banks as promptly as possible:

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"As a part of the Government's program for encouragement of business recovery, the Board of Governors has
reduced reserve requirements on all classes of deposits for
all member banks, effective at the opening of business on
April 16, 1938. By this action excess reserves of member
banks will be increased by about 4;i750,000,000.
"Reserve requirements in effect prior to April 16, 1938,
and thereafter are shown in the following table:

Classes of member banks and
of deposits
Demand deposits:
Central reserve city banks
Reserve city banks
Country banks
Time deposits:
All classes of member banks




Prior to
April 16
0

Beginning
April 16

26
20
14

22-3/4
17-1/2
12

6

Mr. Ransom moved that Mr. Goldenweiser prepare for consideration by the
Board, with a view to publication in an
early issue of the Federal Reserve
Bulletin if approved for that purpose,
a statement setting forth a factual
history of member bank reserve requirements.
Mr. Ransom's recommendation was
approved unanimously.
Mr. Ransom moved that the Division
of Research and Statistics be requested
to study all of the phases of member
bank reserve requirements and that Mr.
Goldenweiser be requested to submit to
the Board for consideration not later
than November 1, 1938, any recommendations that the Division might wish to
make as the result of its study with
respect to changes in the existing provisions of law or regulations relating
to member bank reserves.
Mr. Ransom's recommendation was
approved unanimously.

5"

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-5There were presented telegrams to Mr. Thomas, Chairman of the

Federal Reserve Bank of Kansas City, and Mr. McKinney, President of
the Federal Reserve Bank of Dallas, stating that the Board approves
the

establishment by the Federal Reserve Banks of Kansas City and

Dallas of a rate of 21-r% per annum on advances to individuals, partnerships or corporations secured by direct obligations of the United
States under the last paragraph of section 13 of the Federal Reserve
Act) effective on the first business day following that on which approved by the Board, and the establishment by the banks on April 14,
1938) without other change of the rates of discount and purchase in
their existing schedules.
Approved unanimously.
There were also presented telegrams to Mr. Young, President
of the Federal
Reserve Bank of Boston, Messrs. Kimball, Post and Hays,
Secretaries of the Federal Reserve Banks of New York, Philadelphia
and

Cleveland, respectively, Mr) Leach, President of the Federal Reserve

Bank of Richmond, Mr. McLarin, Vice President of the Federal Reserve
Bank Of
Atlanta, Messrs. Stewart and Powell, Secretaries of the FedReserve Banks of St. Louis and Minneapolis, respectively, and Mr.
Stewart
) Chairman of the Federal Reserve Bank of San Francisco, stating
that the
Board approves the establishment without change by the Federal Reserve Bank of San Francisco on April 12, by the Federal Reserve
Of

New York, Philadelphia, Cleveland, Richmond, St. Louis and




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M
inneapolis on April 1/1, and by the Federal Reserve Banks of Boston
and Atlanta on April 15, 1938, of the rates of discount and purchase
in their
existing schedules.
Approved unanimously.
At this point Messrs. Thurston, Wyatt, Goldenweiser, Smead,
Dreibelbis
and Vest left the meeting and consideration was then given
to each
of the matters hereinafter referred to and the action stated
with respect
thereto was taken by the Board:
The minutes of the meeting of the Board of Governors of the
Federal Reserve System held on April 13, 1938, were approved unanimously,
Letter to the Federal Deposit Insurance Corporation, reading
as

follows:
"Pursuant to the provisions of section 12B of the
Federal Reserve Act, as amended, the Board of Governors
of tae Federal Reserve System hereby certifies that 'The
Union Bank of Commerce Company', Cleveland, Ohio, became
a member of the Federal Reserve System on April 13, 1938,
and is now a member of the System. The Board of Governors
of the Federal Reserve System further hereby certifies
tnat, in connection with the admission of such bank to membership in the Federal Reserve System, consideration was
given to the following factors enumerated in subsection
(g) of section 12B of the Federal Reserve Act:
1. The financial history and condition of the
bank,
2. The adequacy of its capital structure,
3. Its future earnings prospects,
4. The general character of its management,
5. The convenience and needs of the community
to be served by the bank, and
6. Whether or not its corporate powers are consistent with the purposes of section 12B of
the Federal Reserve Act."




Approved unanimously.

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-7Letter dated April 14, 1938, to Mr. Hill, Vice President of the

Federal Reserve Bank of Philadelphia, reading as follows:
"This has further reference to your letter of March
8, 1938, with inclosures, receipt of which was acknowledged
on March 14, 1938, concerning an inquiry from Mr. Sohn C.
Knox, Vice President and Trust Officer, National Bank of
Germantown and Trust Company, Philadelphia, Pennsylvania,
relating to the provisions of section 6 of Regulation F requiring the review of actions of trust department committees
by the directors of a national bank.
"It appears that the trust investment committee of National Bank of Germantown and Trust Company (which also
acts upon the acceptance and closing out or relinquishment
of fiduciary accounts) keeps extensive minutes and that it
is the practice to read such minutes at meetings of the
board of directors and to have the directors approve any
and all actions of the committee. However, the directors
feel that too many details are being brought to their attention for their approval and that too much time is being
consumed in that manner. 14r. Knox inquires how far it is
necessary to go in order to comply with the requirements
of Regulation F.
"Section 6(b) of Regulation F provides, in part, as
follows:
'The board of directors is responsible for
the investment of trust funds by the bank, the
disposition of trust investments, the supervision
of the trust department, the determination of
the policies of such department and for the review of the actions of all committees al22inted
12y the board of directors for the conduct of
the trust department.' (Underscoring added.)
The underscored provision contemplates that the directors
Shall take such action as is necessary to inform themselves
concerning the manner in which the committees are performing their duties and the policies which are being pursued
by the committees.
However, while it definitely places
Upon the directors the responsibility for the review of
the actions of all committees, it does not require that
the directors read all minutes of all committees and
formally approve each and every action taken by the committees. Various methods may be pursued in the proper
discharge of this responsibility; that which is feasible




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"for one bank may not be for another and the action which
should be taken depends upon the particular circumstances
involved. Since the regulation applies to all national
banks, the Board feels that it should not destroy the intended flexibility of this provision by a precise statement
concerning the action necessary to constitute compliance,
but that this should be left to the exercise of sound judgment by individual banks.
"It appears that Mr. Knox has in mind that his bank's
trust investment committee might shorten its minutes in
order to meet the directors' objections. Section 6(c) of
Regulation F requires that the committee 'keep minutes of
all its meetings, showing the disposition of all matters
considered by and passed upon by it' and, after providing
for periodic reviews of assets of each fiduciary account
by the committee, it requires that 'a report of all such
reviews, together with the action taken as a result thereof, shall be noted in the minutes' of the committee. While
the regulation thus requires that the committee keep a
record of all of its activities, it does not attempt to
describe the manner in which the record should be kept.
Clearly, it is not necessary to record verbatim everything
Which is said and to incorporate copies of all memoranda
and other documents considered. However, there is a vast
range between minutes containing unwarranted detail and
those which are so sketchy as to be virtually worthless.
Where the line should be drawn between these two extremes
is a question which also must be left to the sound judgment
of each bank. In deciding this question, however, it should
be borne in mind that the minutes serve purposes other
than to make information currently available to the directors.
, they should provide an adequate record for future
reference, e.g., in the event the bank is called upon to
explain action directed by the committee.
"It appears that both Mr. Knox's letter and your proposed reply perhaps contemplate that the committee approval
of the acceptance of trusts properly may be subsequent to
the actual acceptance of the trusts by the bank. Section
6(b) of Regulation F provides that 'the acceptance of all
trusts shall be approved by the board of directors or a
committee appointed by such board, and the closing out or
relinquishment of all trusts shall be approved or ratified
l
Il ine,
of directors or a committee appointed by such
board , It is believed that this provision clearly requires
approval by the directors or the appropriate committee prior
to the acceptance of a trust.




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-9-

"Since the advice contained in this letter differs in
same respects from your proposed reply to Mr. Knox, it is
suggested that such reply be appropriately modified. The
suggestion that your trust examiner will be glad to discuss
the matter informally seems desirable and, if this suggestion is made, you may find it possible to eliminate from
Your reply some of the general discussion of directors'
responsibilities under Regulation F which goes beyond that
Which is necessary to answer Mr. Knox' specific inquiry."
Approved unanimously.
Letter to Mr. Neely, Chairman of the Federal Reserve Bank of
Atlanta, reading as follows:
"Reference is made to the report of examination of
the Federal Reserve Bank of Atlanta, as of January 28,
1938, a copy of which was left for your information and
the information of the other directors. A copy was also
furnished President Newton. After the report of examination has received the consideration of the board of directors of the Federal Reserve bank, the Board will appreciate
advice as to any action taken or to be taken with respect
thereto, and to other significant matters which may have
been discussed with the management during the course of
examination."
Approved unanimously.
Memorandum dated March 31, 1938, from the Division of Examinetic'he, submitting a draft of a proposed letter to the Presidents of
all

Federal reserve banks requesting them, for the reason stated in

the proposed letter, (1) to prepare promptly an initial list of their
Plac/blem and near problem cases of State member banks; (2) to furnish
the Board with a concise summary of the situation of each bank so
lessed and the corrective action planned or being taken; (3) to subnil.t e
ubsequent reports on developments every 30 days with respect to




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Problem cases and every 90 days with respect to near problem cases;
and (4) to advise the Board of any problem or near problem cases newly
developing

since the previous report.

Mr. McKee had attached a memo-

randum to the file recommending that action by the Board on the proposed
letter be deferred for the present.
Mr. McKee's recommendation was approved unanimously.
Letter to Mr. Thomas, Chairman of the Federal Reserve Bank of
Kansas City, reading as follows:
"Mr. Worthington, First Vice President of your bank,
has suggested that, in view of the arrangement under which
the nonstatutory functions of your office as Federal Reserve Agent have been transferred to the .eederal Reserve
bank, the bond covering you in such capacity should be
reduced. As a result of his suggestion, the Board is requesting the views of the Chairmen and boards of directors
of the other Federal Reserve banks as to the desirability
of reducing the amounts of the bonds covering not only the
Federal Reserve Agents but also the Assistant Federal Reserve Agents, the Alternate Assistant Federal Reserve Agents
and the Federal Reserve Agents' Representatives. A copy
Of the letter dispatched in this connection is inclosed, and
it will be appreciated if, in the light of the comments contained therein, you will forward your views, together with
the views of the board of directors of your bank, regarding
this matter. Please forward also a copy of the bankers'
blanket bond which is in effect at your bank."
Approved unanimously, together with
a letter to the Chairmen of all other
Federal reserve banks, reading as follows:
"The Board now requires an individual surety bond in
the amount of 40.00,000 from each Federal Reserve Agent and
in the amount of 450,000 from each Assistant Federal Reserve
Agent, Alternate Assistant Federal Reserve Agent and Federal Reserve Agent's Representative. In view of the arrangement which has been established at each Federal Reserve bank




428
-11"under which the nonstatutory functions of the Federal Reserve Agent have been transferred to the bank, an officer
of one of the Federal Reserve banks has suggested that the
amount of the bond furnished by the Federal Reserve Agent
Should be reduced.
"It is understood that the bankers' blanket bond which
has been obtained by each Federal Reserve bank specifically
covers the acts of the Federal Reserve Agent and his assistants.
Accordingly, the Board is giving consideration to the desirability of reducing to $10,000 the amount of each individual
bond covering the Federal Reserve Agents and the Assistant
Federal Reserve Agents, the Alternate Assistant Federal Reserve Agents and the Federal Reserve Agents' Representatives.
However, before taking any action on this proposition, the
Board would appreciate an expression of your views, together
With the views of the board of directors of your bank, as to
the desirability of such a change. In this connection, your
attention is invited to the Board's letter of Iune 11, 1924
(X-4083). Please forward a copy of the bankers' blanket
bond which is in effect at your bank."




Thereupon the meeting adjourned.

Chairman.