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476

A meeting of the Board of Governors of the Federal Reserve
System was held in Washington on Tuesday, April 9, 1940, at 10:30
a.m.
PRESENT:

Mr.
Mr.
Mr.
Mr.

Ransom, Vice Chairman
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. Paulger, Chief of the Division of
Examinations
Mr. Dreibelbis, Assistant General Counsel
Mr. Williams, Assistant Counsel
At Mr. Ransom's request, Mr. Williams reported on the legislative status of (1)
bill H.R.6971 and S.2098 to amend the Federal
Home Loan Bank
Act, the Home Owners' Loan Act of 1933 and Title IV
of the
National Housing Act, (2) the Wagner resolution, S. Res. 125,
and (3) the Jones Farm Credit
bill, H.R.8747 and S.3509.

He stated

that it
appeared that the first bill would be taken up on the floor
of the House
this week but that there were no plans for its immediate c
onsideration by the Senate Banking and Currency Committee and
that, if the
bill passed the House, the Senate Committee probably
would want to
hold further hearings on it.
With respect to the Wagner resolution, Mr. Williams said
that he had
been informed that an economist to assist the committee




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in directing the hearings had not been selected and that the questionnaire being prepared by the Senate Banking and Currency Committee to be sent
to various agencies of the Government and other
interested parties could be expected some time next week.
In connection with the Jones Farm Credit bill, Mr. Williams
said that it was expected that a sub-committee of the House Committee on
Agriculture would give consideration next week to the views
expressed at the recent hearings by representatives of the American
Bankers' Association and others as to the bill, that it was not yet
determined whether further hearings would be held on the bill, but
that it was
expected that a decision would be reached next week as
to whether
the bill should be reported out at this session, and,
if scl, in what form.

In this connection it had been indicated that

if reported
out it would be materially amended.
Mr. Ransom stated that, in accordance with the action taken
at the
meeting of the Board on April 5, 1940, he talked over the
telephone

with Mr. Brown, President of the Federal Advisory Council,

With regard
to the statement submitted by the Council at its meeting on November
21. 1939, with respect to bill H.R.6971 to amend
the Federal
Home Loan Bank Act and related legislation, that at Mr.
Brown s
request copies of the statement were sent by messenger to
the

Chairmen of the Banking and Currency Committees of the House

and Senate yesterday and Mr. Brown was so advised by telegram, and




4/9/40
that it was understood from the conversation with Mr. Brown that
he would send copies of the statement direct to the other members
of the Banking and Currency Committees.
Mr. Ransom also stated that, as requested at the meeting
of the Board on
April 5, 1940, Mr. Dreibelbis had revised, and the
individual members of the Board who were present had approved in
the revised
form, the report addressed to Chairman Wagner of the
Senate Banking and Currency Committee on bill S.2098 to amend the
Federal Home Loan Bank Act and related legislation.

He (Mr. Ransom)

suggested
that the approved report be held in the Secretary's office
until Messrs. Dreibelbis and Williams had ascertained that the Banking and
Currency Committee of the Senate was going to give consideration to the bill and had notified the Secretary's Office to that
effect at which time the report would be forwarded to Senator Wagner
IDY messenger.
Unanimous approval was given to Mr.
Ransom's suggestion.
The report, as thus approved, read as follows:
"This is in reply to your letter requesting an opinion as to the merits of S. 2098, a bill 'To amend the
Federal Home Loan Bank Act, Home Owners' Loan Act of 1933,
Title IV of the National Housing Act, and for other purposes.'
"The Board is concerned by the broad implications of
the bill in respect to the probable effect of its enactment upon the banking and credit structure of the country.
Certain of its provisions would expand the permissible
activities of Federal Savings and Loan Associations and




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"other member institutions of Federal Home Loan Banks far
beyond their original character as local mutual thrift and
home-financing associations and would allow them to transact a large amount of general banking business. Other
provisions would, by affording preferential insurance
facilities to the shares of such associations, lend a
degree of liquidity to them comparable to that of bank
deposits. By thus, on the one hand, expanding the types
of business in which such associations could engage so
as to include a large amount of general banking business
and, on the other, making it possible for them to compete
With savings banks and savings departments of commercial
banks and other financial institutions on favored terms,
the enactment of the bill would tend to establish a separate and complete banking system. The question presented
is so important that it would seem that Congress would be
justified in studying this particular step carefully in
its relation to the whole credit and banking structure,
as a part of a comprehensive review of our banking, credit and monetary system such as is contemplated by S. Res.
125.
"It may be helpful to point out in some detail certain sections of the bill which the Board believes raise
the foregoing question of the probable effect of the bill's
enactment upon the banking and credit structure of the
country.
"Sections 1, 2, 8, and 11 of the bill would materially expand the permissible activities of such associations.
"Section I would liberalize the class of collateral
securities upon which Federal Home Loan Banks are authorized to make advances to their member institutions. At
present, mortgages are restricted to 'home mortgages'.
This section would completely eliminate any such restriction and would support any past or future enlargement of
the lending powers of State-chartered member associations,
as well as Federal Savings and Loan Associations by authorizing advances upon the security of any first mortgage.
"Section 2 would further extend the list of eligible
collateral to a materially different class of securities,
Which would include not only obligations of the Federal
Savings and Loan Insurance Corporation and of the Federal
Home Loan Banks, but also any other obligations acceptable
to the Federal Home Loan Bank Board which a member association might lawfully have available.




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-5-

"Section 8 of the bill would allow Federal Savings
and Loan Associations, under proper authorization from the
Federal Home Loan Bank Board, to place 15 per cent of their
assets (in addition to 15 per cent now allowed to be invested in first mortgages with no restrictions) in residential mortgages of any sort - not necessarily !home
mortgages! - within a 50 mile radius. This may be a justifiable change, but the restrictions of that section would
apply only to Federally-chartered institutions. The lending powers of State-chartered institutions are governed by
State law and the amendments proposed in section 1 would
therefore encourage the latter to expand their activities
to other fields instead of continuing as local mutual
thrift and home-financing associations. Therefore, it
would be desirable to place in section 1 restrictions
Upon advances by the Federal Home Loan Banks similar in
terms to those which would be placed in section 8 upon
the types of mortgages in which Federally-chartered associations are authorized to invest.
"Section 8 also would allow Federal Savings and Loan
Associations to invest their assets in any securities
that are legal investments for fiduciary and trust funds
and are approved by regulations of the Federal
Home Loan
Bank Board. This might be justified as permitting associations to employ idle funds when satisfactory home mortgage loans are not available; but there appears to be no
reason for permitting Federal Home Loan Banks to make advances upon such securities, as is done in section 2, if
such securities are to be merely temporary investments
and
the associations
are to continue as home-financing institutions.
"Section 11 of the proposed bill would change the name
Of the !Federal
Savings and Loan Insurance Corporation' to
Federal Savings Insurance Corporation! thereby giving additional impetus to the transformation of the character of
Federal Savings and Loan Associations from a system of
local mutual thrift and home-finan
cing associations into
a separate banking
system.
"Sections 14 and 15 of the bill would afford preferential insurance facilities to the shares of such
associations, lending to them a degree of liquidity comparable
to that of a bank deposit
. The underlying reason for
-11cluding these particular
sections in the bill seems to
pe based upon
an assumed analogy between shares and other
liabilit
ies of Federal and other savings and loan




4/9/40

-6.-

"associations and savings deposits of savings banks and
the savings departments of commercial banks.
"Section 14 would reduce the premium for insurance
for Federal and other insured associations from the present rate of 1/8 of one per cent to 1/12 of one per cent.
"Section 15 of the bill, in the event of a default
by an insured institution, would permit the payment of
Insured accounts to each insured member either by making
available a transferred insured account in another insured institution or 'in such other manner as the Board
of Trustees may prescribe.' It would permit, if the
Board of Trustees so decided, the full payment of insured accounts in cash rather than in the manner now
Provided, to wit: 10 per cent cash, 50 per cent of the
remainder within one year and the balance within three
years in negotiable noninterest-bearing debentures of
the Corporation.
"While it is true that 1/12 of one per cent is the
current rate of the Federal Deposit Insurance Corporation,
the risks of the two types of insurance and the rates
Which should accordingly be charged for such insurance
are not comparable. Such associations for the most part,
are mutual in character. Their assets are normally on
a long-term basis. Their liabilities are evidenced largelY by obligations purchased by individuals seeking to
acquire and hold an investment rather than to make a
deposit.
"The Federal Deposit Insurance Corporation insures
01117 the deposits of banks, and the net worth of banks,
represented by the shareholders' interest in the banks'
capital and surplus funds, protects depositors and the
Corporation. Generally speaking, there is no comparable
cushion in the case of the Federal Savings and Loan Insurance Corporation, whose member institutions are
largely mutual in character and which insures withdrawable or repurchasable shares, investment certificates,
or deposits. Ordinarily, therefore, a smaller percentage
Of losses on the part of one of its insured institutions
Will expose the Federal Savings and Loan Insurance Corporation to loss than will follow in the case of the Federal
Deposit Insurance Corporation. Furthermore, the uninsured
portion of deposits in insured banks, upon which banks
pay premiums, is much greater than the uninsured liabiltY in building and loan associations, which means that
if the premium collected by the Federal Deposit Insurance

I




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"Corporation was calculated with respect to the deposits
insured rather than all deposits the rate of the Federal
Deposit Insurance Corporation would actually be higher
than 1/12 of 1 per cent.
"Individuals invest in the obligations of building
and loan associations because they expect a higher rate
of return than can be obtained in savings banks and the
savings departments of commercial banks. Furthermore
the rates of return permitted to be paid and actually
Paid by the associations upon their insured obligations
are higher than the rates of interest permitted to be
Paid. upon savings deposits. Investors in the associations should not expect to obtain the same degree of
liquidity as in the case of a savings deposit because
such associations, at the present time, are not expected
to be and are not regarded as being,
as liquid as banks.
If their obligations are to be given the liquidity
contemplated by this legislation, the discrepancy in the
rate of return between such obligations and savings deposits will constitute another serious competitive disadvantage for national and State banks and will result
either in the growth of unsound banking practices or in
mortality among the institutions competing with the
favored Federal and other savings and loan associations.
"For the foregoing reasons the Board of Governors
is of the opinion that the enactment of the bill would
not be in the public interes
t."
Mr. McKee then referred to the action taken at the meeting
of the
Board on April 2, 1940, when he was requested to discuss
further with
Mr. Tingfield, Assistant General Counsel, the draft
of report to the
Chairman of the Banking and Currency Committee of
the
Senate relating to the Investment Company Act of 1940.
In

that connection, Mr. McKee reviewe the discuss
d
ions which he and Mr.
,
t Jaeld had had with represe
ntatives of the Securities and Exchange
e°111mi8sion with respect to the suggeste amendme
d
nt to the bill which
would
eliminate any material overlapping in supervision by the




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-8-

Securities and Exchange Commission and the Board of Governors of
investment companies which are also holding company affiliates and
Which have obtained voting permits from the Board, and stated that
it was hoped that
a form of amendment would be agreed upon and that,
if that were accomplished, it would not be necessary for the Board
to make a report on the bill.
There ensued a further discussion of the
draft of report considered at the meeting on
April 2 and it was agreed that Mr. Wingfield
should be requested to redraft the letter along
the lines suggested at the discussion and to resubmit it to the Board for consideration, it
being understood that it would be held pending
the outcome of discussions with representatives
of the Securities and Exchange Commission regarding the suggested amendment.
In response to an inquiry from Mr. Davis, Mr. Williams said
he did
not think there was any likelihood of hearings being held by
the
Senate Banking and Currency Committee on the Jones Farm Credit
bill at this
session unless the bill passes the House and is sent
to the Senate.

Mr. Davis suggested that the Board, for reasons

whioh he outlined, should not undertake
to make a report on the bill
to
the House Committee on Agriculture, but should have a report ready
for
submission
to the Senate Banking and Currency Committee when it
aPPears that consideration will be given to the bill by that
Committee. He added
that members of the Board's staff were working on a
draft of report which would be submitted to the Board in
due course.




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-9There was then presented a draft of letter to the presidents

of all Federal Reserve banks, asking that they prepare and send to
the Board as soon after May
1 as possible information with respect
to the condition of member banks in their respect
ive districts which
are problem or near-problem cases.

The drr,ft of letter had been cir-

culated among the members of the Board for their information before
co
nsideration at this meeting.
In the discussion of the letter which followed, it was
Pointed out by Mr. Paulger that the information request
ed was similar to that
obtained on earlier occasions, and the question was
considered whether a procedure should be established under which
the
information cslled for would be sent to the Board periodically
or currently as
to each bank as the report of examination of the
member bank is
received at the Reserve bank.
It was understood that Mr. Paulger
would revise the letter and resubmit it
to the Board for consideration and that
it would be taken up again at a meeting
when all of the members of the Board are
present.
At this point Messrs. Thurston, Paulger, Dreibel
bis, and
Williams left the
meeting and the action stated with respect to each
of the matters hereina
fter referred to was then taken by the Board:
The minutes of the meeting of the Board of Governo
rs of the
Federal Reserve
System held on April 8, 1940, were approved unani14011817.




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-10Letter to Mr. Young, Vice President of: the Federal Reserve

Bank of Chicago, reading as follows:
"In accordance with the request contained in your
letter of April 6, the Board approves the appointment
of Herschel R. Johnson as an examiner for the Federal
Reserve Bank of Chicago, and, as requested in your letter of April 5, the Board approves also the appointment
of Matthew Francis Lynch as an assistant examiner.
"Please advise us of the effective dates of the
two appointments."
Letter to Mr. Harrison, President of the Federal Reserve Bank
°f New York, reading as follows:
"There is enclosed herewith a letter addressed to
Mr. J. H. Durrell, Senior Vice President of The National
City Bank of New York, interposing no objection to a
Proposal of such bank to open temporary 'Tellers Windows'
in Havana, Cuba, for the purpose of accommodating visitors in connection with the International Conventions of
the Rotarians and the Lions Club. It will be appreciated
lf your Bank will deliver the enclosed letter to Mr.
Durrell at The National City Bank.
"There is also enclosed a copy of such letter, together with a copy of the incoming letter, for your
files."
Approved unanimously, the letter to Mr.
J. H. Durrell, Senior Vice President of The
National City Bank, New York, New York, reading as follows:
"This refers to your letter of March 30, 1940, regarding the proposal of your bank to open temporary
'Tellers Windows' in Havana, Cuba, for the purpose of
accommodating visitors in connection with the International Conventions of the Rotarians and the Lions Club.
"It is noted that the Rotarians are to hold their
International Convention in Havana from June 10 through
June 14, 1940, and in order to furnish special banking
facilities for such occasions your bank proposes to
open a temporary agency or 'Tellers Window' in the




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"Central Gallego Building in which the Rotarians' headquarters is to be located and also one in the National
Hotel. It is also noted that the Lions Club will hold
its International Convention in Havana from July 23
through July 25, 1940, with headquarters at the SevillaBiltmore Hotel, and that you propose to open a similar
temporary agency in that hotel for the accommodation of
visitors.
"You state that the so-called 'Tellers Windows'
will not receive deposits; but that they will cash travelers checks and bank drafts, pay checks on occasion, and
sell or buy exchange and local currency. We also note
that no one of the three temporary offices will be maintained for periods in excess of those stated above and
that no additional equipment will be necessary except
desks.
"If your proposal to furnish banking facilities is
carried out as stated above, the Board will not interpose any objection thereto."
Letter to Mr. Gidney, Vice President of the Federal Reserve
of New York, reading as follows:
"This refers to your letter of March 28, 1940,
transmitting the letter dated March 21, 1940, addressed
to the Board of Governors of the Federal Reserve System
by French American Banking Corporation, New York, New
York, requesting that the Board increase from 12 to 15
times the Corporation's subscribed capital and surplus,
the limit imposed upon the aggregate of all of the CorPoration's acceptances outstanding plus the total of
all deposits held by it, pending a definite determination as to the amount by which the Corporation's general
reserves will be recoverable and the extent to which
the surplus may be supplemented thereby. In transmitting the letter, you recommend that the requested increase in limitations be granted effective for one year,
at the end of which time the present limitation would
again become effective unless the Corporation should
apply for and receive the Board's approval for a continuance of the higher limitation.
"The Board has given careful consideration to the
application of French American Banking Corporation and
to your recommendation made in connection therewith.




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"However, it does not feel that it is desirable to change
the formal limitation at this time.
"In view of the unusual circumstances now existing,
the reported wide fluctuations in the volume of deposits
with the Corporation, and the fact that, to a large extent,
the increased deposits have been offset by balances with
the Federal Reserve Bank of New York, the Board will interpose no objection, for the time being, should the Corporation's aggregate liability exceed the limitation prescribed
in the agreement with the Board. This action is taken with
the understanding that the Corporation will continue to
maintain a condition of liouidity consonant with the nature
of its liabilities, and upon condition that, as of the end
of each month, the Corporation submit to the Board through
the Federal Reserve Bank of New York a report showing as
at the close of business for each day of the month (a) the
amount of the Corporation's total deposits, (b) the amount
of its acceptances outstanding, and (c) the amount of its
collected balances, less any outstanding items of debit to
such balances, with the Federal Reserve Bank of New York
and the member banks with which its reserve funds are
carried.
"It will be appreciated if you will advise the French
American Banking Corporation of the Board's position in
this matter."
Approved unanimously.
LAter to Mr. Worthington, First Vice President of the Federal
Reserve Bank of Kansas City, reading as follows:
.
"Reference is made to your letter of April 3, 1940,
With regard to the stocks of new Federal Reserve notes
of the 1928 series.
.
"In view of the problem of vault space, the Board
will offer no objection to cancellation and shipment to
Washington for destruction of new Federal Reserve notes
of the 1928 series at your branches. Should legislation
he obtained authorizing the Treasury to replace the Federal Reserve notes of the 1928 series with notes without
the gold clause, it is assumed that such authorization
would include notes destroyed under the conditions set
forth in your letter, provided an adequate record is




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"kept of the serial numbers by denominations of the notes
cancelled.
"In this connection, it may be mentioned that at certain other Federal Reserve bank branches steps have been
taken to relieve the pressure for vault space by cancelling Federal Reserve notes of the 1928 series and sending
them to Washington for destruction as outlined above."
Approved unanimously.
Letter to Mr. Clarke L. Fauver, Assistant Editor, Federal
Home Loan Bank Review, Federal Home Loan Bank Board, reading as follOWs:

"In response to your letter of March 271 there is
enclosed a statement showing (1) real estate loans on
residential properties, and (2) residential properties
owned, as reported by member banks at the end of December,
19381 and June and December, 1939, by States."
Approved unanimously.

Thereupon the meeting adjourned.

kaProved:




Vice Chairman.