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9 Minutes for August 15, 1966 To: Members of the Board From: Office of the Secretary Attached is a copy of the minutes of the Board of Governors of the Federal Reserve System on the above date. It is not proposed to include a statement With respect to any of the entries in this set of minutes in the record of policy actions required to be maintained pursuant to section 10 of the Federal Reserve Act. Should you have any question with regard to the minutes, it will be appreciated if you will advise the Secretary's Office. Otherwise, please initial below. If you were present at the meeting, your initials will indicate approval of the minutes. If You were not present, your initials will indicate only that you have seen the minutes. Chm. Martin Gov. Robertson Gov. Shepardson Gov. Mitchell Gov. Daane Gov. Maisel Gov. Brimmer 016N-7 Minutes of the Board of Governors of the Federal Reserve System on Monday, August 15, 1966. The Board met in the Board Room at 10:00 a.m. PRESENT: Mr. Mr. Mr. Mr. Mr. Robertson, Vice Chairman Shepardson Mitchell Daane Brimmer Sherman, Secretary Kenyon, Assistant Secretary Bakke, Assistant Secretary Holland, Adviser to the Board Molony, Assistant to the Board Fauver, Assistant to the Board Brill, Director, Division of Research and Statistics Mr. Solomon, Director, Division of Examinations Mr. O'Connell, Assistant General Counsel Mr. Goodman, Assistant Director, Division of Examinations Assistant Director, Division of Leavitt, Mr. Examinations Mr. Smith, Assistant Director, Division of Examinations Messrs. Forrestal and Via, Senior Attorneys, Legal Division Mr. Dahl, Chief, Special Studies and Operations Section, Division of International Finance Messrs. Egertson, Supervisory Review Examiner, and Poundstone, Review Examiner, Division of Examinations Mr. Mr. Mr. Mr. Mr. Mr. Mr. Approved letters. The following letters, copies of which are attached under the respective item numbers indicated, were approved unanimously following consideration of background information that had been made available to the members of the Board and explanatory comments by the staff: 2974 8/15/66 -2Item No. Letter to First Chicago International Finance Corporation, Chicago, Illinois, granting consent for an investment in BOECC (Holdings) Ltd., London, England. 1 Letter to the Chairman of the House Committee on Banking and Currency reporting favorably O R. 16503, a bill to amend the Bank H°1ding Company Act to repeal certain exemptions and to extend its coverage to one-bank holding companies. 2 Letter to the Federal Reserve Bank of Atlanta r egarding administration of the discount window. 3 Direct verification (Items 4 and 5). At the meeting on August 12, 1966, the Board considered a draft of letter to the Federal Reserve Banks r garding a proposal for direct verification of a percentage of assets and liabilities, under stated circumstances, during examinations of State member banks. Pursuant to comments made during that discussion, the staff was requested to prepare an appropriate revision for the Board's consideration at a subsequent meeting. There had now been distributed a revised draft of letter in which the Reserve Banks would be advised that: (1) direct verification on a samPle basis should be undertaken at each examination in instances where a State member bank was found not to have reasonably adequate internal controls or audit procedures; (2) State supervisory authorities should ° informed of these plans, with a view to securing their cooperation and assistance; (3) efforts to encourage State member banks to institute 8/15/66 -3- their own programs of direct verification should be continued and intensified; and (4) sight posting of incoming items from cash letters and local clearings should be made a routine part of each examination, unless the internal controls and audit coverage of the bank were such as to make the practice unnecessary. Mr. Solomon commented that it was contemplated that the draft letter, in such form as the Board might ultimately approve, would be tr ansmitted to the Presidents of all Reserve Banks for their information, and that the Chairman of the Conference of Presidents would be requested, In a companion letter, to schedule the subject for consideration at the September 12 meeting of the Conference, following which the Board would d iscuss the subject with the Presidents. He added that although at the Board discussion of the direct verification proposal on August 12 it had been suggested that the National Association of Supervisors of State Banks be informed of the contemplated examining procedure and the views c) State supervisors invited, action along such lines would appear to be Premature at this time. the Notification might better be deferred until matter had been discussed with the Presidents. Governor Brilluuer noted that the revised draft letter took the P°sition that direct verification should be a mandatory part of examinations where State member banks' internal controls or audit procedures were not satisfactory. Previously the proposal had been cast in terms f offering this service at a member bank's option. In light of this, 8/15/66 -4- he thought perhaps the draft letter should include reference to the considerations that had led to the change in the Board's position. Discussion of this point developed an explanation that the Presidents had been kept generally aware of developments since the direct verification procedure was first proposed. Additionally, they would receive, as attachments to the draft letter, copies of a letter regarding the experience of the Dallas Bank in furthering the direct verification program and of the Comptroller of the Currency's recent instructions to all regional administrators of national banks. Therefore, it would seem that the Presidents would be adequately prepared for discussion with the Board following the September 12 meeting of the Presidents' Conference. Further discussion developed certain suggestions for editorial changes in the revised draft letter, which was thereupon approved unani111°11sly in a form incorporating those suggestions, with the understanding that a letter would also be sent to the Chairman of the Conference of Presidents requesting consideration of the subject at the September 12 meeting of the Conference. Copies of the letter to the Chairman of the Pre sidents' Conference and of the draft letter, in the form approved, are attached as Items 4 and 5, respectively. Application of Central State Bank (Items 6 and 7). There had been distributed drafts of an order and statement reflecting the Board's a pproval on August 8, 1966, of the application of Central State Bank, Elkader, Iowa, for permission to acquire the assets and assume the liab ilities of Volga State Bank, Volga, Iowa. 2977 8/15/66 Following adoption of an editorial change in the statement, issuance of the order and statement was authorized. Copies of the docu- ments, as issued, are attached as Items 6 and 7. Request for access to FOMC records. Reference was made to a letter dated August 12, 1966, from Chairman Patman of the House Committee Om Banking and Currency requesting that that Committee and its staff be given access to the minutes and other records of the Federal Open Market C°mmittee. Attached were copies of an exchange of correspondence between Chairman Patman and Chairman Moss of the Subcommittee on Government Information and Foreign Operations (House Committee on Government Operations), regarding the question of the applicability of the disclosure provisions °f P- L. 89-487 (the so-called "Freedom of Information" law) to Open Market Committee records. In his August 12 letter to the Board, Chairman ila trflan stated that "While I know that the law does not become effective until July 4, 1967, the intent of Congress to remove the present shrouds Of secrecy from the operations of the Federal Open Market Committee is clear- the Therefore, I hope that you will immediately make available . minutes and other records of the . . Committee." It was understood, after a preliminary discussion, that a draft Of rePly to Chairman Patman's letter would be prepared on the basis of suggestions made by members of the Board, for consideration at a subsequent meeting of the Board. The meeting then adjourned. 4),A, 4.0k 8/15/66 -6Secretary's Notes: There had been received at the Board's offices an agreement executed under date of August 5, 1966, by First Foreign Investment Corporation, Miami, Florida, in accordance with the requirements of section 25 of the Federal Reserve Act. Accordingly, pursuant to the procedure contemplated by Board action on July 19, 1966, there was sent today to The First National Bank of Miami, Miami, Florida, a letter (copy attached as Item No. 8) granting permission to that bank to invest in stock of First Foreign Investment Corporation and granting permission to the latter corporation to invest in stock of Miami Holdings Limited (title changed from First National Holdings Limited), a Bahamian corporation. Governor Shepardson today approved on behalf of the Board memoranda recommending the following actions relating to the Board's staff: Salar increases Gena Gander, Employment Technician, Division of Personnel Administrat --lon, from $7,942 to $8,479 per annum, with a change in title to rer sonnel Technician, effective August 15, 1966. Sudelle Rice, Employee Development Technician, Division of sonnel Administration, from $7,729 to $8,218 per annum, with a hange in title to Personnel Technician, effective August 15, 1966. Per Transfers 0, Ruth H. Goodyear, from the position of Secretary to the position Personnel Assistant in the Division of Personnel Administration, with change in basic annual salary at the rate of $8,368, effective August 15, 1966 4 . Glenn L. Hogle, from the position of Personnel Technician to the to isltion of Personnel Specialist in the Division of Personnel Administra, with an increase in basic annual salary from $8,218 to $9,221, '-cfective August 15, 1966. Po . Charles W. Wood, from the position of Personnel Assistant to the t.sltion of Personnel Specialist in the Division of Personnel Administra2,:°n, with an increase in basic annual salary from $11,685 to $12,873, zfective August 15, 1966. v.4 8/15/66 -7- Jeanette E. Devlin, Personnel Records Technician, Division of versonnel Administration title changed to Personnel Assistant, with , no change in basic annual salary at the rate of $7,253, effective August 15, 1966. Joseph H. Hoyle, Employee Relations Technician, Division of Personnel Administration, title changed to Personnel Assistant, with no change in basic annual salary at the rate of $8,948, effective August 15, 1966. Margaret H. Wolverton, Personnel Assistant, Division of Personnel Ad nistration, title changed to Personnel Specialist, with no change ln 1966basic annual salary at the rate of $10,481, effective August 15, 25, SO BOARD OF GOVERNORS Item No. 1 8/15/66 OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20531 ADDRESS OFFICIAL CORRESPONDENCE TO THE BOARD August 15, 1966. First Chicago International Finance Corporation, 38 South Dearborn Street, Chicago, Illinois. 60690 Gentlemen: As requested in your letter of July 22, 1966, the Board of Governors grants consent for your Corporation ("FCIFC"), to Purchase and hold 22,058 common shares, 13,127 preferred shares, and to exercise convertibility rights to acquire 8,935 additional common shares to which you may become entitled as holder of convertible loan stock of BOECC (Holdings) Ltd., London, England, at a total cost of approximately $222,000. The Board also approves the acquisition of shares of EOECC, within the terms of the above consent, in excess of 10 per cent of FCIFC's capital and surplus. Please advise the Board of Governors as provided in Section 211.8(d) of Regulation K of any share acquisitions made under the above consent. • The foregoing consent is given with the understanding that the investment now being approved, combined with other foreign loans and investments of your Corporation, will not cause the total of such loans and investments to exceed the guidelines established under the voluntary foreign credit restraint effort now in effect and that due consideration is being given to the Priorities contained therein; especially as stated in paragraph 3 of Guideline (4), it is expected that the outstanding amount of nonexport credits to developed countries in Continental Western Europe would not be increased during 1966 but rather would be reduced to the extent needed to meet bona fide requests for priority credits within the overall ceiling. Very truly yours, (Signed) Karl E. Bakke Karl E. Bakke, Assistant Secretary. 2981 BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM Item No. 2 8/15/66 WASHINGTON OFFICE OF THE VICE CHAIRMAN RESt-.' ••••••• August 15, 1966 The Honorable Wright Patman, Chairman, Committee on Banking and Currency, House of Representatives, 20515 Washington, D. C. Dear Mr. Chairman: This is in reply to your letter of August 1, 1966, in which you asked for a report on H.R. 16503, a bill to amend the Bank Holding Company Act of 1956 to repeal the exemption for labor, agricultural, and horticultural oneorganizations and to extend coverage under the Act to bank holding companies. As you will recall, the Board of Governors has repeatedly recommended legislation incorporating both of tions these changes, and the House adopted these recommenda year this Senate the in passing H.R. 7371 last year but Congress rejected them. Presumably, this means that the 89th 16503. H.R. in embodied changes will not act on the two Nevertheless, the Board continues to believe that these recommendations are sound in principle, and we are hopeful that in time they will be enacted. Accordingly, the Board supports H.R. 16503. Sincerely, (Signed) J. L. Robertson J. L. Robertson 2982 BOARD OF GOVERNORS Item No. 3 8/15/66 OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20551 ADDRESS orriciAL CORRESPONDENCE TO THE BOARD August 15, 1966 Mr. Harold T. Patterson, President, Pederal Reserve Bank of Atlanta, A tlanta, Georgia 30303. Dear Mr. Patterson: The Board has just received an excerpt from the report °f the recently concluded examination of the Federal Reserve Bank of Atlanta relevant to the administration of the discount window. From this it appears that the pattern of borrowing in the Atlanta District may not be consistent with Regulation A, and the present stance of monetary policy. The examination report notes that the documentation !-11 the files of the Discount Department is insufficient and that borrowing banks may not have been communicated with in a timely fashion. The Board has your letter of August 9, 1966, and understands that the entire matter was to be reviewed by the Executive Committee °f your Board. It would be appreciated, therefore, if you would inform _Lille Board as promptly as possible regarding the Executive Committee's u iscussion of the matters referred to with particular reference to the "nclusions reached and actions planned or taken. Very truly yours, (Signed) Merritt Sherman Merritt Sherman, Secretary. 29S1 BOARD OF GOVERNORS Item No. 4 8/15/66 OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20551 ADDREBB OFfICIAL CORRESPONDENCE TO THE BOARD August 17, 1966 Edward A. Wayne, Chairman, Conference of President s, Federal Reserve Bank of Richmond, Richmond, Virginia. 23213 Dear Mx. Wayne: The Board would appreciate your having placed on the agenda for consideration at the forthcoming meeting of the Conference of ! residents the enclosed draft of letter to all Federal Reserve Banks egarding the subject of direct verification of assets and liabiliti es n connection with examinations of State member banks. l You will recall that in the Board's letter of June 11, 1965, (Si - 0tan th F.R.L.S. 3595) the Reserve Banks were requested to encourage :"e use of direct verification programs. In that connectio n there is ' tnclosed, in addition to the proposed letter to be sent by the Board o 411 Reserve Banks, a copy of a letter from President Irons of the Fed e eral Reserve Bank of Dallas dated July 14, 1966, regarding the AlitPerience of that Bank in furtherin g the direct verification program. :Ica° enclosed for your convenient reference is a copy of a memorandum i Of nstructions issued under date of July 21, 1966, by the Comptroller the Currency to all regional administrators of national banks. In addition to asking the Conference of Presidents to review this , dis Letter at its meeting on September 12, the Board would like to with the Conference this subject at an appropriate time, probableu" Y during the afternoon of September 13. For your information, the Board also has in mind addressing an an st_FPropriate letter to the National Association of Supervisors of di'Le Banks at the time that its letter to all Reserve Banks is thatibtd for inclusion in the loose-leaf service, the substance of i_ communication being to solicit the assistance of the Supervisors " the program of direct verification. 2984 Mr• Edward A. Wayne Because of the length of time between now and the date for meeting of the Conference of Presidents, and also because of the .1ength of the enclosures, a copy of this letter with attachments is .eing sent direct to each Reserve Bank President for his information 7:!I. with the comment that the Chairman of the Conference has been 4 ked to have the matter placed on the agenda for the forthcoming laeeting.. the 1 Sincerely yours, (Signed) Merritt Sherman Merritt Sherman, Secretary. Etitl° ure )85 Item No. 5 8/15/66 8/15/66 PROPOSED LETTER TO ALL FEDERAL RESERVE BANKS ON DIRECT VERIFICATION Dear Sir: In the Board's letter of June 11, 1965, (5-1960, F.R.L.S. 3595), the Reserve Banks were requested to develop certain informati°n about direct verification by State member banks, to discuss the lack of such program when appropriate, and to encourage the use of direct verification programs. Direct verification of assets and liabilities is clearly desirable, and it is now believed that the System should undertake direct verification at each examination in instances where the State Ilember bank does not have satisfactory internal controls and audit Programs. To accomplish this objective the Reserve Banks are requested to inform all State member banks that the Federal Reserve 8Yatem will, during each examination and at its expense, verify irectly a percentage of the assets and liabilities of the bank unless internal control and audit programs are considered reasonably adequate. The Reserve Bank should inform State bank supervisory aut horities of these plans for direct verification, and every effort hould be made to obtain the cooperation and assistance of the State banking departments. Efforts to encourage State member banks to institute their 13141 Programs of direct verification as referred to in the Board's letter of June 11, 1965 should be continued and intensified. -2 29S6 For your information there are enclosed a copy of a letter from President Irons of the Federal Reserve Bank of Dallas dated July 14, 1966 commenting about that Bank's experience with direct verification, and a copy of instructions to all Regional Administrators from the Comptroller of the Currency, dated July 21, 1966, regarding the applicability of audit and verification procedures. A letter dated June 22, 1962, from Mr. Frederic Solomon to Vice Presidents in Charge of Examinations, included a memorandum "titled "Examination Procedures Useful in Investigating Possible irregularities in Small Banks.'! Among other practices mentioned in the memorandum is that of sight posting. This is considered so effective a method of uncovering irregularities in deposit accounts that the practice of sight posting incoming items from cash letters and local clearings is to be made a routine part of each examination "less the internal controls and audit coverage of the bank are such as to make this practice unnecessary. Very truly yours, Merritt Sherman, Secretary. Enclosures: 2 2987 Item No. 6 8/15/66 UNITED STATES OF AMERICA BEFORE THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. In the Matter of the Application of 411TRAL STATE BANK aPProval of acquisition of assets of' State Bank ORDER APPROVING ACQUISITION OF BANK'S ASSETS There has come before the Board of Governors, pursuant to the Ilerger Act, as amended (12 U.S.C. 1828(c), Public Law 89-356), an 1t •1 by Central State Bank, Elkader, Iowa, a State member bank °f the rederal Reserve System, for the Board's prior approval of its 4echa. sition of assets and assumption of deposit liabilities of Volga Stat tank, Volga, Iowa, and, as an incident thereto, Central State ra; , nas applied, under section 9 of the Federal Reserve Act, for the 130 ardt S prior approval of the establishment by that bank of a branch 4t the location of the sole office of Volga State Bank. Notice of the h0 11°sed acquisition of assets and assumption of deposit liabilities, t ()tm approved by the Board, has been published pursuant to said Act. Upon consideration of all relevant material in the light Ot the the factors set forth in said Act, including reports furnished by Comptroller of the Currency, the Federal Deposit Insurance Corporation, 2and the Attorney General on the competitive factors involved in the Proposed transaction, IT IS HEREBY ORDERED, for the reasons set forth in the lIctrd ls Statement of this date, that said applications be and hereby Qe aPproved, provided that said acquisition of assets and assumption fdaPosit liabilities and establishment of the branch shall not be tclIsummated (a) before the thirtieth calendar day following the date °Z this Order, or (b) later than three months after said date. Dated at Washington, D. C., this 15th day of August, 1966. By order of the Board of Governors. Voting for this action: Governors Robertson, Shepardson, Mitchell, Daane, and Brimmer. Absent and not voting: Governor Maisel. Chairman Martin and (signed) Merrit'z Sherman Merritt Sherman, Secretary. 2989 Item No. 7 8/15/66 APPLICATION BY CENTRAL STATE BA= FOR APPROVAL OF ACQUISITION OF ASSETS OF VOLGA STATE BANK STATEMENT The Central State Bank, Elkader, Iowa ("Central Bank"), /1-th total deposits of about $6.9 million, has applied, pursuant to the Bank Merger Act, as amended (12 U.S.C. 1828(c), Public Law 89-356), fc'r the Board's prior approval of its acquisition of the assets and assumption of the liabilities of Volga State Bank, Volga, Iowa 1/ (701ga Bank"), which has total deposits of $640,000.— As an incident to the transaction, the sole office of Volga Bank would become a branch of Central Bank, increasing the number of its offices to three. Competition. - The head office of Central Bank is in Rikader, a town with a population of about 1,600, which is the seat of CieYton County. The bank operates a branch about seven miles north of 44ader at St. Olaf, a community with a population of less than 200. The 431e office of Volga Bank is in Volga, a community with a population ' Of about °-- AO, which is about 12 miles southwest of Elkader. The relevant area for considering the competitive effects Of th e Proposal consists of the central and southern portions of Clayton COL Lnt Y and a narrow portion of eastern Fayette County. In this area, igur S are as of April 5, 1966. 2990 -2eight offices of six banks compete in varying degrees with Central 8ank, or with both Central Bank and Volga Bank. The total of 11 effices, operated by eight banks, altogether hold deposits of about $23 million and total loans of approximately $10 million. Central Ilank, with about 27 per cent of the deposits and about 24 per cent Of the loans, is the largest bank in the area. Volga Bank, with about 3 per cent of the deposits and about 1 per cent of the loans, i8 the smallest bank in the area. The second, third, and fourth largest banks hold approximately 23 per cent, 14 per cent, and 13 per cent, respectively, of area deposits. The banking offices in the relevant area, because of their size and their location in an agricultural region, tend to 4411 the preponderance of their business from the communities in Ilhich they are situated. It does not appear that any of these Offices would be adversely affected by the proposed transaction, 11hich would not materially alter the structure of banking competition in the area. There is some competition between Central Bank and 6a Bank, This competition is facilitated by the location of 41zadp -r as the nearest trading center to Volga, and by the fact that '1 number of Volga residents commute to work in Elkader. The extent Of the competition is limited by the size and nonaggressive policies Of v0lga Bank. Further, as discussed hereinafter under the banking 21391 -3- factors, it is unlikely that Volga Bank, if it remains an independent in stitution, will become a more effective competitive force because its location limits its earnings prospects and growth potential. The effect of the proposed transaction on competition would not be adversz. Financial and managerial resources and future prospects. The financial condition of Volga Bank is satisfactory and its capital Position is relatively strong. However, the bank's earnings record is below average, partly as a result of its operating policies and partly because of the economy of the Volga community. In recent Years Volga has experienced a marked decline in population relative to the over-all experience for Clayton County. The community is not a trading or marketing center, and its prospects for growth appear limited. These circumstances restrict the opportunity for Volga Bank to grow and, in turn, make it improbable that a capable successor can be found for the bank's chief operating officer, who iS Jell past the normal retirement age. The prospects for Volga 8ank are not favorable. The banking factors, as they relate to Central Bank, are satisfactory and would not be adversely affected by the proposed acquisition of Volga Bank. Convenience and needs of the communities. - The banking c"venience and needs of Elkader and St. Olaf would not be appreciably affected by the proposed acquisition. The principal effect would be 2992 -4in Volga, where a small unit bank would be replaced by a branch office Of a larger and more progressive institution. The resulting benefit from these features for the banking convenience and needs of the e°111munity may be offset to some extent by local restrictions on branch bank operations. Under State law, branch offices are confined to accepting deposits and paying checks, and are required to refer loan aPplications to the head office. However, in view of the prospects for Volga Bank and for the community it serves, and in the light of the bank, s management succession problem, there is a considerable question as t° how long Volga Bank can realistically be expected to continue as 4 Unit the bank. Thus, the proposal would have the advantage of assuring continuance of a banking facility for the Volga community. _Summary and conclusion. - In the judgment of the Board, the Pl'°110sed transaction would benefit the banking convenience and needs Of the Volga area, and would not result in any significantly adverse %sequences for banking competition. Accordingly, the Board concludes that the application Should be approved, Autust 15, 1966. BOARD OF GOVERNORS Item No. 8 8/15/66 OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20551 ADDRESS OFFICIAL CORRESPONDENCE TO THE BOARD August 15, 1966 The First National Bank of Miami, 100 South Biscayne Boulevard, Miami, Florida. Gentlemen : This refers to the application of your bank dated June 6, 1966, for permission of the Board of Governors under the provisions Of Section 25 of the Federal Reserve Act, to purchase and hold stock of First Foreign Investment Corporation, Miami, Florida ("First ti.oreignu). Reference is also made to the agreement dated August 5, 1966, executed by First Foreign in accordance with the requirements of Section 25 of the Federal Reserve Act, by which such corporation agrees to restrict its operations and conduct its business in the manner set forth therein. After consideration of the application and agreement, the Board of Governors of the Federal Reserve System approves the application and grants permission to The First National Bank of Miami, Miami, Florida, subject to the provisions of Section 25 of the Federal Reserve Act, to purchase and hold stock in First Foreign in the amount of a pproximately $300,000. Please advise the Board of Governors, through the Federal Reserve Bank of Atlanta, the date First Foreign commences business. The Board of Governors also grants consent for First Foreian to purchase and hold approximately 30 per cent of the capital : : t 3ck of Miami Holdings Limited, a Bahamian corporation, at a cost ' 0 a pproximately US$300,000, provided such shares are acquired within ne Year from the date of this letter. The Board also approves the Purchase and holding of such shares in excess of 10 per cent of rirst Foreign's capital and surplus. ited The foregoing consent for investment in Miami Holdings Limis given with the understanding that the investment, combined with BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM 2994 The First National Bank of Miami -2- 1oreign loans and investments of The First National Bank of Miami, will not cause the total of such loans and investments to exceed the guidelines established under the voluntary foreign credit restraint effort now in effect and that due consideration is being given to the priorities contained therein. Very truly yours, (Signed) Karl E. Bakke Karl E. Bakke, Assistant Secretary.