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La 609

10/59

Minutes for

To:

August 261 1960

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.




Chin. Martin
Gov. Szymczak
Gov. Mills
Gov. Robertson
Gov. Balderston
Gov. Shepardson
Gov. King

49'17..A.A *

Minutes of the Board of Governors of the Federal Reserve System
on Friday, August 26, 1960.
PRESENT:

Mr.
Mr.
Mr.
Mr.

The Board met in the Board Room at 9:00 a.m.

Balderston, Vice Chairman
Szymczak 1/
Robertson
Shepardson
Mr. Kenyon, Assistant Secretary
Miss Carmichael, Assistant Secretary
Mr. Young, Adviser to the Board
Mr. Fauver, Assistant to the Board
Mr. Hackley, General Counsel
Mr. Noyes, Director, Division of Research and
Statistics
Mr. Farrell, Director, Division of Bank Operations
Mr. Solomon, Director, Division of Examinations
Mr. Sammons, Associate Adviser, Division of
International Finance
Mr. Nelson, Assistant Director, Division of
Examinations
Mr. Goodman, Assistant Director, Division of
Examinations
Mr. Smith, Assistant Director, Division of
Examinations
Mr. Poundstone, Federal Reserve Examiner, Division
of Examinations

Discount rates.

On August 11, 1960, the Board authorized the

Secretary's Office to advise the respective Federal Reserve Banks of
aPProval of a discount rate of either
established by such Banks.

3 per cent or 3-1/2 per cent, as

The rate for all of the Federal Reserve Banks

except Dallas and San Francisco having now been changed from 3-1/2 per cent
to

3 per cent, the suggestion was made that the Board revert to the usual

Procedure for consideration of rate wires from the Federal Reserve Banks
but continue the authorization to the Secretary's Office to advise of
4PProva1 of a

3 per cent rate for the Dallas and San Francisco Reserve Banks

1f and when wires were received from those Banks requesting such approval.
1?,_
Withdrew from meeting at point indicated in minutes.




3284
8/26/60

-2Agreement having been expressed with this suggestion, the Board

authorized the Secretary's Office to advise of approval of a 3 per cent
rate at the Dallas and San Francisco Reserve Banks, if established by
those Banks.

The Board then approved unanimously the establishment with-

out change by the Federal Reserve Banks of New York, Cleveland, Richmond,
Minneapolis, Kansas City, and Dallas on August 25, 1960, of the rates on
discounts and advances in their existing schedules, with the understanding
that appropriate advice would be sent to those Banks.
Items circulated or distributed to the Board.

The following items,

Which had been circulated or distributed to the Board and copies of which
are attached to these minutes under the respective item numbers indicated,
were approved unanimously:
Item No.
Letter to Chemical Bank New York Trust Company,
New York City, approving the establishment of a
branch in Massapequa, Nassau County.

1

Letter to The First National City Bank of New York,
New York City, approving the establishment of a
branch in the Newport area of San Juan, Puerto Rico.

2

Mr. Nelson then withdrew from the meeting.
Federal Advisory Council topics.

A draft of letter to the

Secretary of the Federal Advisory Council suggesting topics for inclusion

Oh the agenda for the meeting of the Council to be held on September 14,
1960, and for discussion at the joint meeting of the Council and the
130ard on September 15 had been distributed.




8/26/60

-3Following a general discussion during which several changes in

wording and possible additional topics were suggested, it was agreed that
a revised draft of letter would be prepared for consideration by the
Board.
Messrs. Young and Noyes then withdrew from the meeting.
Examination of Bank of America, New York (Item No. 3).

A memo-

randum from the Division of Examinations dated June 30, 1960, regarding
the report of examination of Bank of America, New York, made as of
November 25, 1959, had been circulated.

It was pointed out in the memo-

randum that a copy of the report had been transmitted to Bank of America
With a letter from Chief Examiner Pierce of the Federal Reserve Bank of
New York dated March 2, 1960, which called attention to the examiner's
comments on page 2 of the report and requested correction of certain
violations of Regulation K, Corporations Doing Foreign Banking or Other
Foreign Financing under the Federal Reserve Act.

In a letter dated May 6,

1960, the Executive Vice President of Bank of America advised the Federal
Reserve Bank of New York that the examination report had been presented
to the board of directors on April 18, 1960, and had been carefully
reviewed by the auditing and examining committee and by executive officers.

The letter reported certain corrective actions taken on the matters referred
to by the examiner.

Attached to the June 30 memorandum was a draft of

letter to Bank of America commenting on the following items covered by

the examination report: (1) nonconforming loans and credits; (2) nonconforming deposits; (3) audits or inspections of Banca d'America e d'Italia;




-4-

8/26/60
and

(4) suggestions and recommendations regarding certain provisions of

Regulation K made by former Executive Vice President Russell G. Smith
Of Bank of America in a letter dated March 14, 1958.
Commenting on the problem of nonconforming loans, Mr. Goodman
indicated that there was criticism of some of the loans of Bank of
America because they appeared to be of a domestic character rather than
for the purpose of financing international transactions.

In connection

With nonconforming deposits, the letter would refer to an account of the
Zim Israel Navigation Co., Ltd., which the examiner had mentioned in
his report, indicating that the "various checks drawn against this account
were used to pay office expenses in the United States."

According to

information furnished by Mr. Coughran, the checks "referred to by the
examiner were used to pay expenses of vessels incurred while engaging in
international trade and to refund deposits of passage money on cancelled
trips."

On the basis of this information, the letter would indicate that

such activity would be consistent with Regulation K.
Also, the letter would state that no objection would be interposed
to the maintenance of deposit accounts for foreign steamship lines whose
Inain offices were located abroad where drawings against such deposit
accounts were related solely to shipping expenses incurred in United
States ports, such as towing costs, lighterage, piloting, pier costs, and
Other incidental expenses, including provisioning of vessels.

It would

easo reaffirm the views expressed by the Board in its letter of October 14,
1958, to the effect that deposit accounts for domestic customers, including




8/26/6o

-5-

Panamanian or Liberian shipping corporations which maintain their main
offices in the United States, would be in violation of Regulation K.
Commenting on the 1958 ruling, Mr. Goodman said Bank of America
had been informed at that time that even though the deposit accounts
involved had certain international characteristics, the acceptance of
such accounts was not considered by the Board to be permissible under the
Federal Reserve Act and Regulation K.

Section 25(a) of the Federal Reserve

Act provides that Edge Act corporations shall have the power "to receive
deposits outside of the United States and to receive only such deposits
Within the United States as may be incidental to or for the purpose of
carrying out transactions in foreign countries or dependencies or insular
Possessions of the United States."
Mr. Solomon observed that the proposed letter would say, in effect,
that deposit accounts were not in violation of Regulation K as long as a
foreign steamship company was concerned.

If a domestic company or any

Other company having its main office in the United States was involved,

the transactions would be in violation of Regulation K.

He noted that

Vice President Crosse of the Federal Reserve Bank of New York was of the
°Pinion that the nature of the transaction itself rather than the domicile
cif the company engaged in the transaction should be considered.

It was

Ilecessary, Mr. Solomon thought, to draw the line some place and no point
seemed entirely logical.

It could be said that none of the deposit

accounts involving shipping expenses incurred in United States ports were




8/26/60

-6-

permissible, that all of them were permissible, or that some were and
some were not.

A number of the steamship companies were clearly foreign;

Others were clearly domestic; and some, such as Panamanian and Liberian
companies with main offices in the United States, were technically foreign
but might still be considered domestic.
Mr. Solomon said he would be inclined to reaffirm the position
taken in 1958 and indicate that if a navigation company's headquarters
were abroad it could maintain deposit accounts with an Edge Act corporation;
If the company was domestic, it could not maintain such accounts.

This,

he said, would be one place to draw the line.
Mr. Hackley commented that there were arguments on both sides of
the question and it was difficult to know where to draw the line.

He

would be inclined to have the appropriateness of an account determined on
the basis of whether or not it was reasonably incidental to carrying out
foreign transactions.
Governor Szymczak and Mr. Sammons withdrew from the meeting at
this point to attend a meeting of the National Advisory Council on Interaational Monetary and Financial Problems.

Before leaving, Governor

SzYmczak indicated that he would be inclined to agree with the proposed
letter to Bank of America and, in the matter of the maintenance of deposits
for steamship companies, to favor a test based on the nationality of the
company concerned.

He added, however, that he did not regard the question

as particularly important.




8/26/6o

-7In reply to a question raised by Governor Shepardson, Mr. Solomon

said that the restrictions placed on the domestic activities of Edge Act
corporations had their basis in the prohibition against interstate branch
banking in the United States.

In this case the theory was that Bank of

America, New York, a subsidiary of Bank of America National Trust and
Savings Association, San Francisco, should be limited in the scope of
its operations to those functions of an international character for which
it was organized.

This got into the difficult question of defining how

far Bank of America should be allowed to go in competing with American
banks in New York.
Governor Robertson expressed the opinion that the specific
question being considered was not too important.

The amount of business

involved was not large enough to be of too much concern to the Board or
domestic banks one way or the other.

In view of the international trade

flavor which was involved, he would be inclined toward the liberal side.
Governor Shepardson said it seemed to him that a clear line might
be drawn at the waterfront.

A ship in port is still afloat, and the

aecessary provisioning of such a ship would appear to be an incident of
international trade, as opposed to the building or repairing of vessels
at shipyards.

For these reasons, Governor Shepardson indicated that he

14°ul4 agree with the position taken by Governor Robertson.
Governor Balderston concurred and noted that Governor Szymczak,
although inclined toward the other view, had expressed the thought that
the question was not too important.




329(
8/26/60

-8After further discussion, it was agreed that the paragraphs

regarding deposit accounts for steamship lines should be rewritten to
reflect the majority view of the Board.
Mr. Goodman then referred to the portion of the proposed letter
Which would indicate that Banca d'America e d'Italia, an Italian banking
subsidiary, should be audited periodically by the Controller of the
Bank of America, New York, the Controller of the Bank of America National
Trust and Savings Association, or by independent accountants.

He noted

that Bank of America had indicated in a letter dated July 28, 1960, that
regular examinations were conducted by inspectors of the head office of
Banca d'America e d'Italia and that additional periodic examinations by
the Controller of Bank of America, other than reviews of executive and
administrative head office reports, were not considered necessary.

Mr.

Goodman said that the procedure suggested by Bank of America would not
appear acceptable from the standpoint of good supervision.

He felt that

the Board should require inspections such as indicated in the proposed
letter, although he did not think it was necessary to spell out how often
such inspections should be made.
After further discussion, it was agreed that the portion of the
letter to Bank of America relating to inspections of Banca d'America e
d 'Italia reflected the position that should properly be expressed.
Consideration then was given to that part of the letter which
14ou1d comment on various recommendations regarding provisions of




8/26/60

-9-

Regulation K that had. been included in a letter dated March 14, 1958,
from Mr. Russell G. Smith, formerly Executive Vice President of Bank of
America.

Question was raised whether it was necessary for the Board to

comment on matters raised in 1958 by an officer no longer with Bank of
America; also whether a general discussion of Regulation K should be
reopened in a letter concerning an examination report.
Mr. Goodman indicated that the thought had been to clear up at
one time all of the questions that had been raised with respect to the
Operations of Bank of America but had not as yet been answered.

He

indicated,however, that he had no strong feeling on this point,

ana

in

further discussion it was noted that the present officers of Bank of
America could, if they so desired, present any comments or suggestions
to the Board.
Thereupon, the letter to Bank of America, New York, with the
Changes agreed upon during the foregoing discussion, was approved unanimously.

A copy is attached as Item No.

3.

Messrs. Goodman and Poundstone withdrew at this point.
Report of examination of Minneapolis Reserve Bank (Item No.

4).

Mr. Smith summarized the report of examination of the Federal Reserve
Bank of Minneapolis made as of May 18, 1960, and there followed a general
discussion of matters relating to the report.
During the discussion, consideration was given to the extent of
Use of the Minneapolis Reserve Bank's discount window by First National




8/26/60

-10-

Bank of Minneapolis and Northwestern National Bank of Minneapolis, and
the suggestion was made that a letter be sent to the President of the
Reserve Bank requesting, for the record, a statement concerning the
reasons underlying the borrowings of these member banks, the Foministrative
measures used in dealing with the situation, and the nature of current
and prospective developments. There being agreement with this suggestion,
it was understood that a letter would be prepared and sent when in a form
satisfactory to Governor Balderston.
Secretary's Note: A copy of the letter sent
to the President of the Federal Reserve Bank of
Minneapolis on September 71 19601 is attached
as Item No. 4.
In the course of further comments on the examination of the
Minneapolis Bank, Mr. Smith stated that during this examination the field
examining staff had for the first time follawed the procedure, suggested
bY Price Waterhouse & Co., of observing the actual conduct of an audit
Performed by the Reserve Bank's auditing staff.

Representatives of Price

Waterhouse had participated in the review, but it was not the present
intent to call upon the firm further.

Two additional reviews of this

nature had since been conducted, and the reactions to the procedure
appeared satisfactory on the part of the auditing departments concerned
and the Board's examining staff.

Therefore, it was planned to make such

reviews on a regular basis for an indefinite period.
Report of examination of Kansas City Reserve Bank (Item No. 5).
Mr. Smith summarized the report of examination of the Federal Reserve Bank




8/26/60

-11-

of Kansas City made as of April 21, 1960, and there followed a general
discussion of matters relating to the report.
During the discussion, consideration was given to information
in the report concerning the extensive use of the Reserve Bank's discount
'window by nine reserve city banks and 23 country banks. It was suggested
that a letterebould be sent to the Federal Reserve Bank of Kansas City
requesting advice as to the circumstances underlying this use of Reserve

Bank credit and the administrative measures employed by the Bank to
encourage member banks to adjust their affairs so as to avoid frequent
recourse to the Reserve Bank's discount window.

There being agreement

with this suggestion, it was agreed that such a letter should be prepared
and sent when in a form satisfactory to Governor Balderston.
Secretary's Note: A copy of the letter sent to
the President of the Federal Reserve Bank of
Kansas City on September 7, 1960, is attached
as Item No. 5.

The meeting then adjourned.
Secretary's Notes: Governor Shepardson today
approved on behalf of the Board the following
items:
Memorandum dated August 22, 1960, from Mr. Noyes, Director, Division
of Research and Statistics, requesting authorization to enter into a
contract with the Bureau of the Census to furnish the Board with the
industrial codes assigned to major manufacturing establishments, at an
estimated cost of $11,000, to be used in connection with the electric
Power project which was approved by the Board in 1959.
Letter to the Federal Reserve Bank of Cleveland (attached Item No. 6)
aPproving the appointment of Bernard L. Reed as assistant examiner.




Assistant Secretary/

3294
BOARD OF GOVERNORS
e$19 VI toc44,
V,
90 t
; ',
.!'
3
44
v

OF THE

item No. 1
8/26/60

FEDERAL RESERVE SYSTEM

*
*
o
o
o

WASHINGTON 25. D. C.
ADDRESS

orricoAL

CORRESPONDENCE

TO THE BOARD

tro:11. 4.131,
40404.*

August 26, 1960

Board of Directors,
Chemical Bank New York Trust Company,
New York, New York.
Gentlemen:
Pursuant to your request submitted through
the Federal Reserve Bank of New York, the Board of
Governors of the Federal Reserve System approves the
establishment of a branch in the Holiday Park
Shopping Center, northwest corner of Hicksville Road
(Route 107) and Jerusalem Avenue (Route 105)0
Massapequa, Nassau County, New York, by the Chemical
Bank New York Trust Company, New York, New York.
This approval is given provided the branch is
established within one year from the date of this
letter.




Very truly yours,
(Signed) Kenneth A. Kenyn
Kenneth A. Kenyon,
Assistant Secretary.

if

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM

Item No. 2

8/26/6o

WASHINGTON 25. D. C.

ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

August 261 1960

The First National City
Bank of New York,
55 trail Street,
New York, New York.
Gentlemen:
The Board of Governors of the Federal Reserve System
authorizes The First National City Bank of New York,
New York,
Wew York, pursuant to the provisions of Secti
on 25 of the Federal
Reserve Act, to establish a branch in the Newpo
rt area of San Juan,
Puerto Rico; and to operate and maintain
such branch subject to the
Provisions of such Section. The location of the
branch may not be
hanged, after establishment, without the prior
appro
val of the
Board of Governors.
The Board of Governors also grants its consent
to the
exercise by The Firs
t National City Bank of New York, at the Newport
!rea branch, of any
of the fiduciary powers heretofore granted it by
Board of Governors pursuant to Section 11(k)
of the Federal
4?serve Act. This consent is grant
ed on the condition that the exerlse of such powers in Puerto
Rico is not in contravention of the local
:
i4 811 and that in exercising
such
powers at its Newport area branch the
)k shall
comply in all respects uith the applicable provi
sions of the
'ederal Reserve Act and the Regulation
s of the Board of Governors.
Unless the branch is actually established and
bus.
opened for
lness on or before September 1, 1961,
all rights granted hereby
be deemed to have been abandoned
and the authority hereby granted
ill automatically termi
nate on that date.
Please advise the Board of Governors, in writi
the m,
ng, through
zeder
al
Reserve Bank of New York, when the branch is
busiopened for
-`"ess, furnishing information as to the exact
location of the branch.




Very truly yours,
(Signed) Kenneth A. Kenyon
Kenneth A. Kenyon,
Assistant Secretary.

f

ar)r)Or.
t

BOARD OF GOVERNORS
Nwge%
\

OF THE

Item No. 3

FEDERAL RESERVE SYSTEM

IA

8/26/60

WASHINGTON 25. D. C.

ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

1
kfte0
44440*

August 26) 1960

40. Jesse W.
Tapp,
?,hairman of the Board,
of America,
Broad Street,
411 York, New York.
near

pir.

Tapp:
Reference is made to the following:

(1) Report of examination of Bank of America,
New York, made as of November 25, 1959, by
an examiner for the Board of Governors;
(2) Letter dated March 2, 1960, addressed to you
by Chief Examiner John F. Pierce of the Federal Reserve Bank of New York, transmitting
the report;
dated Nay 6, 1960, from Executive Vice
President Coughran to the Federal Reserve
Bank of New York, advising the report was presented to the Board of Directors on April 18,
1960, reporting corrective actions taken, and
commenting on violations reported.

(3) Letter

The
Board of Governors has been pleased to note the corrections effected.
DEteet. „ With respect to loans and credits listed as nonconforming on
41(b) to 11(b)-(2)„ consideration has been given to the comments
ot
0011Te examiner in the light of additional information furnished in Mr.
4W'ran's letter. Mil-) each of the underlying transactions has chart° eristics international or foreign in nature, it is the view of the
olld that the transactions in question do not conform to the provisions
egulation K. Mere transactions have domestic beneficiaries, it is
cloill°1:tant
"'3
that transactions handled by Banking Corporations be free from
cloltle as to whether the primary consideration is the financing of the
be .; 8tie beneficiary rather than the underlying transaction, which may
tr,flternational or foreign in character. This would be the case in
pol'",sactions such as those described for account of Foreign Credit Coration, The Deltec Corporation, and Transport Commercial Co.




4'. Jesse W.
Tapp
With respect to advances to Radio Corporation of America to
Plarchase Deutsche narks, it is not felt that the financing of a foreign
:
)
“*Lange transaction for a United States firm would qualify under
ction 6(d)(1). In other words, while Regulation K authorizes a BanktlIg Corporation to buy and sell spot and future foreign exchange, such
, ,sactions should be on a cash basis only, as Er. Coughran's letter
'
41ortsses it, when the transaction ceases to be a contingent obligation
represents an actual outlay of funds. horeover, it is felt that
"
bc1.
made to United States firms to purchase foreign exchange should
2L-r2.91.
1i related to international or foreign transactions in order
'
4) conform to the letter as well as the spirit of Regulation K.

r

Ni. Coughrants comments have been noted with respect to various
Pland accounts reported as nonconforming. It appears that most of the
beritiaizedaccounts for depositors domiciled in the United States have
reen closed or brought into apparent conformity with Regulation K. With
irlect to Zim Israel Navigation Co., Ltd., Haifa, Israel, account, it
tk4n0ted that, although the examiner stated "Various checks drawn against
account were used to pay office expenses in the United States",
ecIrding to Er. Coughran the checks "referred to by the examiner were
ta,!! to pay expenses of vessels incurred while engaging in international
tcua and to refund deposits of passage money on cancelled trips". On
b,e basis of this information, it would appear that such activity would
:0 consistent with Regulation K. This is related to questions raised
tecrning Nonconforming Deposit Accounts in the report of examination
ill nur Bank as of December 4, 1958, regarding which Vice President Ralph,
n1S letter of May 15, 1959, stated in part:

4

W

"It is felt that towing costs, lighterage, piloting, pier
costs and other incidental expenses in domestic ports are
an integral part of the costs of operating ships in international or foreign transportation. It is logical, therefore, that an activity which would be considered incidental
to our international or foreign business where a credit ext:ension is involved, would also be considered conforming even
111 the absence of a credit extension."
In the Board's letter of October 14, 1958, regarding the report
Of e
re ZaMination as of November 22, 1957, the following comment was made
ilje ding demand deposit accounts of domestic customers listed as
'
Aconforming:
"It will be noted that ten of the accounts ... are those
?f steamship companies or their agents in New York. In some
Instances, the depositors, including a few Panamanian or




Jesse N. Tapp

-3-

"Liberian companies, maintain their main offices in New
York, while other depositors act as agents for foreign
companies whose principal offices are abroad. Those
Shipping company accounts usually are used solely in conjunction with disbursements necessary in the operation
of foreign flag vessels calling at American ports. It
appears that the Corporation considers such accounts to
be conforming. Nhile the shipping accounts
might in a
sense be said to arise in connection with international
business, the acceptance of such deposit accounts is not
considered by the Board to be permissible under the Federal
Reserve Act and Regulation K at an office of an Edge Act
Corporation in the United States.0
Consideration has been given to the position expressed in the
aboli
e quoted remarks of Vice President Ralph and
the Board is impressed
NA41
oct --Ls analysis notwithstanding the position taken in its letter
of
pe,21Der 14, 1958. Accordingly, even in the absence of credit and other
atritted relationships, no objection will be interposed
to the mainten%
,e of deposit accounts for steamship lines engaged
in international
to Irice where drawings against such deposit accoun
ts are related solely
N.
:
121-Pping expenses incurred in United States ports which are
directly
d to such expenses as towing costs, lighterage, piloti
ng, pier
83 and other incidental expenses, including
provisioning of vessels.
On page 2 of the report, the examiner commented that there had
beeh
'
rriaa no audits by independent accountants
nor on-the-spot inspections
Ne of Banca diAmerica e
(BAI) since the stock was acquired.
sorlalexaminer suggested that adequate inspections
be made either by perof your bank, its parent, or outside accoun
tants. Regarding this
MT. Coughran has stated:
,!The
1
Italian Banking Supervisory Authorities in the person
of
he Governor of the Banca
d'Italia have informed our management that they consider the condit
ion of the Banca d'America
e d'Italia as excellent. We have been furthe
r informed that
they have arrived at
this evaluation through their own sources
Of information and that this method
of evaluation applies to
411 Italian banks. The Italian Banking Superv
isory Authorities
?IllY conduct an examination of banks when in their opinio
n it
le nepessary to do so.




Josce T. Tapp

3299

to provide for control
"We feel that we have adequate measures
be asked to
of the bank's operation and that we should not
ired of other Italian
incur additional expense If:rich is not requ
tage."
banks, and which would place us at a disadvan
the Board's letter of
This general question was mentioned in
ran at the time consent
!Y, 20, 1960, to 7,xecutive Vice President Cough
ch and seven agencies
granted to the establishment by BAI of a bran
questions addressed
t various Italian cities. Reference was made to two
27, 1956, and his reply of
111'. Piero.""i in the Board's letter of July
the questions:
411Nst 2, 1956, with the following co:ament regarding one of
115.

ica's supervision
What would be the nature of Bank of Amer
operations of BAI be
of BAD Would investment and credit
of Bank of America?
supervised in same manner as branches
periodically examine
Would the controller of Bank of America
the head office and branches of LIAI?

the corporate structure
"It is intended to implement, within
policies as
of BAI, substantially the same investment and credit
far as pracas
ica,
Amer
are applicable to the branches of Dank of
It is
ons.
lati
regu
and
ticable and consistent with Italian laws
rvise
supe
to
ods
e meth
.!'Urther contemplated to develop appropriat
ies.
polic
such
with
rdance
Investment and credit operations in acco
e
offic
head
the
The same would apply to periodic examinations of
"
ica.
Amer
and branches of BAI by the controller of Bank of

Th
,
.
extent you have
be:tioard's letter of Nay 20 reouested advice as to the practices followed.
nt
curre
your expectations and the

\,017.1 able to carry out
decision as to the nature
will appreciate, of course, that the Board's
e to have conducted by its own
extent of examinations of BAI it may desir
be placed on the supervision
Z.!•;Illiners will depend on the reliance that may
ance that may be gained from
14 control of BAI internally; and also the assur
examinations, regarding the
)rmation available in New York, during periodic
311“
cted by or on behalf of
,Pervision and independent inspections of BAI condu
r Bank.
4
, included this comment:
Er. Coughran's reply of July 281 1960
Deputy Controller of
• .. between April 1958 and March 1960,
to PL for the
Bank of America, alliam Ihriale, was assigned
edures, personnel policies
Purpose of evaluating operational proc
also of assistance to RAI.
Fa' internal auditing procedures. He was
which he deemed desirable.
In placing into effect various changes
year period which included
As a result of his experience over a two
rted on the adea regular program of branch review, Er. Eitriale repo
of BAI. Regular examinations
quacy of the internal auditing procedures
an adequate manner
by inspectors of Head Office of RAL are conducted in
controller of Bank of
and additional periodic examinations by the
tive and administrative Head
America, other than reviews of execu
y at this time."
Office Reports, arc not considered necessar
In
acquire the stock of BAI, the Board
eranting consent to Bank of America to
sq• alea,
e and branches of BAI
that periodic examinations of the head offic
the case of overseas
in
as
"-td be made by the Controller of Bank of America



3390

Mr. Jesse W. Tapp
-5br
anches of Bank of America and Bank of America NT&SA. Although careful
.?onsideration has been given to Mr. Coughranfs reply, the Board neverthe"rss still feels that it is desirable that BAI be examined periodically
the Controller of Bank of America or the Controller of Bank of America
or independent public accountants. It is requested that this matter
eL7. brought before the Board of Directors of Bank of America for considert'lon and the Board of Governors advised as to your plans in this regard.




Very truly yours,
(Signed) Kenneth A. Kenyon
Kenneth A. Kenyon,
Assistant Secretary.

BOARD OF GOVERNORS
i;,4tztitztto.,

* VI;

OF THE

qapr,'L4-,t

FEDERAL RESERVE SYSTEM

Item No. 4

8/26/60

WASHINGTON 25. D. C.

ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

m.4$

September 7, 1960
Mr. Frederick L. Deming, President,
Federal Reserve Bank of Minneapolis,
Minneapolis 2, Minnesota.
Dear Mr. Deming:
In considering the report of examination of the Federal
Reserve Bank of Minneapolis as at the close of business May 18, 1960,
as well as other information in the Board's files, the protracted use
Of your Bank's discount window by the First National Bank of Minneapolis
and the Northwestern National Bank of Minneapolis has been noted. A
review of their respective borrowing records, dating from July 1959,
shows that the First National Bank has been indebted in all but 4 of the
61 reserve computation periods that have elapsed from that date to
August 24, 1960; the Northwestern National Bank has been indebted in 48
reserve computation periods during the same term, including 21 consecutive periods during 1960. These figures would seem to present a question
Whether the borrowings of these banks from the Federal Reserve Bank are
consonant with the principles set forth in the foreword to Regulation A.
The Board recognizes that the question of appropriateness of
member bank borrowing from a Federal Reserve Bank depends on the circumstances peculiar to each case. Hence, it will be appreciated if you will
:
aclvise the apparent cause for the inability of these large banks to adjust their asset positions so as to avoid such consistent recourse to the
Reserve Bank's discount window, the administrative actions taken by your
Bank in these particular cases, and an estimate as to how soon these
banks may be able to follow the more normal course of operating within
their own resources over an extended period.




Very truly yours,

6,4f.
Kenneth A. Kenyon,
Assistant Secretary.

9
1)
13
1-

BOARD OF GOVERNORS
OF THE

Item No.

FEDERAL RESERVE SYSTEM

5

8/26/60

WASHINGTON 25, D. C.

ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

September

7, 1960

Mr. H. G. Leedy, President,
Federal Reserve Bank of Kansas City,
Kansas City 6, Missouri.
Dear Mr. Leedy:
The report of examination of the Federal Reserve Bank of
Kansas City as at the close of business April 21, 1960, at pages
39-51, listed 9 reserve city banks and 23 country banks that had
made extensive use of the Reserve Bank's discount window during
1959 and in the current year to date of examination. It is observed that all nine of the reserve city banks borrowed in 70 per
cent or more of the reserve computation periods in both 1959 and
the portion of the current year to date of examination, and that
a majority of these banks borrowed in 80 per cent of the reserve
computation periods. Thirteen country banks borrowed in 70 per
cent or more of the reserve computation periods in 1959; one of
these banks was indebted on every day of the year, and another one
was indebted 345 days. Sixteen of the country banks borrowed in
seven or more of the nine reserve computation periods that had
elapsed in the current year to date of examination and, of these,
siCht borrowed in all nine of the periods.
The Board is desirous that the legitimate credit needs
Of the member banks be served, but is concerned whether the borrowlngs from the Reserve Bank summarized above are consonant with the
general principles set forth in the foreword to Regulation A. The
Bcard would appreciate it if you would review the situation and
advise it with respect to (a) the circumstances underlying the extensive use of Reserve Bank credit and (b) the administrative
measures employed by the Reserve Bank to encourage the member banks
to adjust their affairs so as to avoid frequent recourse to the
ileserve Bank's discount window. If the same underlying causes




330:7,
Mr. H. G. Leedy

Pertain to groups of banks, it is not necessary that you reply in
detail with regard to each bank separately. However, if an individual bank was faced with special circumstances, the Board would
be interested in learning the particulars in each such instance.




Very truly yours,
J77-71417)a. 44-5
,
--7,1-)
Kenneth A. Kenyon,
Assistant Secretary.

•

.1"*;
5
'

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM

Item No. 6

8/26/60

WASHINGTON 25, D. C.

ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

August 26, 1960

Mr. Paul C. Stetzelberger, Vice President,
Federal Reserve Bank of Cleveland,
Cleveland 1, Ohio.
Dear Mr. Stetzelberger:
In accordance with the request contained in
Your letter of August 22, 1960, the Board approves the
appointment of Bernard L. Reed as an assistant examiner
for the Federal Reserve Bank of Cleveland. Please
advise as to the effective date of the appointment.




Very truly yours,
(signed) Kenneth A. Kenyon
Kenneth A. Kenyon,
Assistant Secretary.

•