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1510 A meeting of the Board of Governors of the Federal Reserve SYstem with the Chairmen of the 1. ederal Reserve banks was held in Washington on Tuesday, December 5, 1939, at 10:00 PRESENT: Mr. Mr. Mr. Mr. Mr. Mr. a•Me Eccles, Chairman Ransom, Vice Chairman Szymczak McKee Davis Draper Messrs. F. H. Curtiss, Owen D. Young, T. B. McCabe, G. C. Brainard, Robert Lassiter, W. T. Nardin, and R. B. Caldwell, Chairmen of the Federal Reserve Banks of Boston, New York, Philadelphia, Cleveland, Richmond, St. Louis, and Kansas City, respectively Messrs. R. E. Wood, W. C. Coffey, Tay Taylor, and St. George Holden, Deputy Chairmen of the Federal Reserve Banks of Chicago, Minneapolis, Dallas and San Francisco, respectively 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 Goldenweiser, Director of the Division of Research and Statistics Mr. amead, Chief of the Division of Bank Operations Mr. Paulger, Chief of the Division of Examinations Mr. Parry, Chief of the Division of Security Loans Mr. Dreibelbis, Assistant General Counsel Mr. Thomas, Assistant Director of the Division of Research and Statistics Mr. Conklin, Senior Economist in the Division of Research and Statistics Mr. Thompson, General Assistant in the Secretary's Office 1511 12/5/39 -2After welcoming the Chairmen to the meeting, Mr. Eccles reviewed the actions which had been taken by the System in the Government securities market because of unsettled conditions which acc°mPenied the outbreak of hostilities in Europe. He discussed brierlY the considerations which prompted the purchase of securities dullng the period of market decline and the subsequent sales of Sefrom the System account. In this connection he called at- tention to the fact that the System open market account is now analler than when the policy of allowing bills to run off ut replacement was adopted last June, so that recent operations ill the account, taken as a whole, have had no material effect upon the reserve position of member banks. He also discussed the reasons r(Ir tho large excess reserve position of member banks and expressed the °Pinion that with the present strong indications of continued €(3341 1: '°113°rts there was little likelihood of a chanrze in this situatiot °r in general money market conditions in the near future. Mr. Goldenweiser was then called upon to make a statement th r espect to the discount rates at the Federal Reserve banks with DEtrti °Illar reference to uniformity of rates at all Federal Reserve gke • A memorandum of the important points covered in Mr. GoldenWet a -eri s statement has been placed in the Board's files. IvEi In response to an inquiry from Mr. McCabe as to whether it sireble to have more uniformity in the discount rates of the -1512 12/5/39 Federal Reserve banks than we have at the present time, 'qr. GoldenWei ser expressed the opinion that these rates should be uniform for the reason that the money market is a national and not a local one elld the discount rate should be related to the open market rate. also He expressed the opinion that the rates for advances under section 10(b) of the Federal Reserve Act should be uniform and should not eceed the regular discount rate by more than the one-half per cent l'ecIllired by law and that the requirement of that differential should be eliminated at the first opportunity. He observed that for a number „ Years the question of discount rates at the Federal Reserve behks has been largely academic inaamuch as member banks have not bee " uorrowing and, while situations may arise where it would be dezi rabic to have different discount rates in different districts, he _Lei+ p stron.Ely that in the present situation they should be unirorm 14 all districts and that now was a good opportunity to adopt that policy when the question of rates was not important. Chairman Eccles added that it would be a desirable situation to heva the discount rates at a low level at this time so that when the time comes to increase the rates the desired psychological eftect ) c f rate increases can be obtained without increasincz rates to 4 high level. DUrin6 a discussion of the possible relation of the discount e t sPeculative conditions in a district or generally throughout tbe laati°n, Mr. Parker, President of the Federal Reserve Bank of 1513 12/5/39 -4- Atlanta, joined the meeting. The Board had been advised of the in- ebilitY of Mr. Neely to be present because of illness and that the Other pl kd-LaSS C directors were also not available. In the circum- stances, Mr. Neely arranged for Mr. Parker's attendance with the ePProIral of the Board. Mr. Curtiss referred to the second part of the topic of d'iseount rates of Federal Reserve banks which related to discusbetween the Board of Governors and directors of Federal Re"re banks of reasons for changes in discount rates, and stated til "it had been the custom of his bank in the past to send a letter to the Board stating the reasons which prompted the board of directors of the bank to make a change in the bank's discount rate. Morrill stated that this phase of the topic had been suggested the Purpose of raising the question of the desirability of indiscussion between the Board of Governors and the directors th e Federal Reserve banks of the reasons for Particular changes 14 a, ''seount rates before those changes are actually made. Mr. Goldenweiser then introduced Mr. Conklin of the Division Or leseerch and Statistics who has charge in the Division of the IEltietic al information collected through the Federal Reserve banks "4 Mr- Conklin made a statement with respect to the collection and 414t1sis of current information by the Federal Reserve banks and the 11(3111* AEU.imnay of Mr. Conklin's statement has also been placed in t46 riles. 1514 12/5/39 -5During a discussion of the purpose of the Board in collect1118 this information and the efforts being made to perfect available bilsiness statistics, Mr. -Ransom inquired of Mr. Thomas whether he hd yzu, ataggeSt CMS to offer as to how we could obtain better infor- 11111tion than we are getting at the present time. Mr. Thomas referred t0 the existing understanding with the Commerce Department that that , enn-4-41nent will expand its activities with respect to statistics on Iliall4fe,cturing and said that the Division of Research and Statistics did llot regard it as its responsibility to collect regularly statisties, -Lor industry but preferred to take the information developed tile Department of Commerce, various trade associations, and other °1s8anizations, and to analyze that information as currently as possible , 'Or indications of trends, to ascertain what questions the data do 11°t answer, and to try to develop the answers to specific questions thrco "gh direct contacts or otherwise. In response to an inquiry as to whether the Federal Reserve b 4k v'ere cooperating in the collection of the information desired 13Y- the Board, Mr. Thomas stated that the banks were giving excellent >cl)eration. In this connection, Mr. Goldenweiser stated that the e411131en were in a position to be of a great deal of help to the bY takin-g a special interest in the activities of the Federal lesellre banks in this field. Chairman Eccles called on the Chairmen for such comments or '44;esti.°11s as they might wish to make with respect to this topic. 1515 12/5/39 -6- The comments of the Chairmen included the suggestion that a tremendous enleunt of information is being requested by Government agencies of '4111011s kinds and it would be a very great help to industry, and there l'1°111d be less difficulty in getting cooperation from industry if this information could be collected through a central point; that the objectives of the statistical function might be more clearly defined; that the in dustrial activities in the various IJederal Reserve districts are different and the problem would have to be handled differently in the different districts; and that there was a question as to the extent to Which the information collected should be used in making forecast, The opinion was also expressed that the information was not "tained and analyzed quickly enouAl to serve the purposes of the 8Y- t and that it should be gathered and distributed more rapidly. It 1,,,„ the general opinion of the Chairmen that the policy of the SYst i e- -n expanding its activities in this field was a desirable one, that ' t was helpful to the officers and directors of the Federal Ree banks; and that the banks would gladly cooperate in carrying on the h°14 " The suggestion was also made that there should be a closer CEItEirt- between the research departments of the banks and the Board's cin of Research and Statistics and that it would be well to have 1110.1„e f l'eqUent meetings of the personnel at the Federal Reserve banks 4- this work and the Board's Division of Research and Statistics Wie,s1,4 ' 44neton, In that connection a suggestion was made that temporary Ces Of economists between benks might be helpful. It was stated • 12/5/39 -7- thElt the question of the more effective collection of statistical int('Itletion by Government agencies was in the process of being studied b/r the Central Statistical Board and that any forecasts made by the slon of Research and Statistics were confidential and were not released to the public. At 1:00 p.m. the meeting recessed and reconvened at 2:00 p.m, it the sane attendance as at the morning session except that Mr. Davi Was not present. In connection with the topic which was under discussion when the recess was taken, Mr. McCabe suggested that representatives of the card visit the various Federal Reserve banks and discuss with the di rectors the program of the Board for the collection and analyel e of uusiness information and the way in which the respective FedReserve banks can cooperate in developing ways in which the 'ed information can be collected. At the conclusion of the discussion of this topic, Messrs. Thome. 8 end Conklin left the room. Mr- Paulger made a statement with respect to the relation -t, be 4eerl the auditors of the Federal Reserve banks and the board of 44ctors and of the value of current audit reports and discussions til"ec/t by the directors. A summary of this statement has been 114eed in the files. At the conclusion of Mr. Paulger's statement, Mr. Brainard 1_517 12/5/39 -8- quired to whet extent employees in the auditing department might be Used in other departments of the bank, and it was stated that there was no reason why permanent transfers to and from the auditing department should not be made and that there was no objection to Illetabers of the auditing staff rendering assistance to the nonoperating de Pertments of the bank, such as examination, personnel, or research clePartments. Following an inquiry by Mr. Taylor relating to Mr. Paulger's "etement that there had been few losses as the result of irregularities 14 the l'ederal Reserve banks Mr. Eccles raised the question whether, °la the basis of the Federal Reserve banks' loss experience, it would be "eeper for the banks to adopt a program of self-insurance. Kr. TieEpa 't stated that a survey of the insurance practices of the Federal 0e banks was now in progress which it was hoped would develop the necessary information for a decision on this point. In response to an inquiry frolnlVIr. Ransom whether the Chair144 h any comments to make with respect to information which they Eq.e Ow receiving from the auditors, Mr. Wood suggested that the - ePorts and the reports of examination made by the Board's exkine„ ' 8 be made shorter or that they be supplemented by brief sume, Mr. Goldenweiser withdrew at this point. On the question of the relation of the auditor to the board or ciir "tors, Mr. Young stated that the procedure now being followed 1511. 12/5/39 -9_ bY the Federal Reserve Bank of New York had been found to be very satis factory to the directors and had resulted in an independent stat118 for the auditor. He stated that the bank has an auditing commit- tee e°11sisting of the Chairman and two other directors appointed by the Chairman to serve for periods of three months; that the auditing c()Draittee meets with the auditor after the first of each month; and that he (Mr. Young) did not know of anything that gives the directors Ils (/(:)cl a picture of the operations of the bank as the review of the E41dit reports at these meetings. He added that the auditor not only l'ePc3rts to the auditing committee, but the salaries of all of the orricers and employees in the auditing department are fixed by the 41rect°ra quite independently of the executive officers of the bank. vr this procedure, Mr. Young stated, the Chairman reports to the Of directors, calling attention to anything that is developed br 41, u4e auditinr committee that it is felt should be brought to the ention of the board, but that otherwise the board of directors ' - en is not called upon to act upon the audit reports although they ars available to any director. At this point, upon inquiry by Mr.. Nardin, it was stated that it was the practice at all of the Federal Reserve banks to have the €`11(litor report directly to the board of directors independently Of th e aXecutive officers and that this procedure was the usual thing it a "°n1Marcial bankiwr practice. 1519 12/5/39 -10Mr. Nardin asked whether there was any objection to the ex- eitive officers of the bank sitting with the auditing committee, the auditors' reports were discussed and it was agreed that there wee It _ uot only no objection to such an arrangament but, on the contrary, was ordinarily desirable to have the President and possibly some or the other executive officers present. Further discussion brought out the fact that at some of the _ l Reserve banks any directors who are available are invited to be .pre sent during the discussion of audit reports and in some cases the . tiuditor discusses a report before the entire board of directors. At the conclusion of the discussion Mr. Eccles stated that the i mportant thing brought out by the discussion was that the auclitor - Was responsible to the board of directors of the bank and 811°111d be independent of the operating officers and that it was not the PlIrPose of the Board of Governors in discussing this matter to Ilreseribe the way in which the audit function at the bank should be 13"1'°11med. Mr. McCabe referred to the audit by outside auditors which „, h'u had made of the Federal Reserve Agent's accounts at the time he bee alaa Chairman and Federal Reserve Agent and was requested to receipts for collateral for outstanding notes and for unissued Pedeliti Reserve notes in the Federal Reserve Agent's department, and t hEit he was continuing to have checks made by outside auditors 1V5/39 • -11- Would continue that procedure unless advised by the Board that it was not necessary or desirable. Mr. Young stated that it had been the position of the board • di rectors of the Federal Reserve Bank of New York that it was the l'esPonsibility of the examiners for the Board of Governors to check 413 on the Federal Reserve Bank auditors at the time of the annual e'erainations of the Federal Reserve banks and that if the audits were 11(It being made in a satisfactory manner it was the opinion of the clil'ectors that the Board's examiners should ascertain that fact and • a the directors accordingly. Mr. McCabe questioned whether the annual examination made "lia Board's examiners would meet the point he had in mind because • the Possibility of something happening between examinations. Mr. Pala, t,er stated that the Division of Examinations would be glad to selvi an examiner to Philadelphia at any time to make any check that 141' 'McCabe thought might be desirable. Mr. Eccles commented that the Board's examiners are specialists i, auditingr and exPmininE the accounts of the Federal Reserve ' - 8 and for this reason should be more competent than an outside accountants in this work, and that if at any time the Chair- wo '°111d feel that the Board's examiners were not performing their k 1, 8 satisfactory manner, the Board should be advised. Mr. Szymczak referred to the fact that the Board has recently "oke d the policy of rotating the examiners in charge of examinations 12/5/39 -12- °I' the Federal Reserve banks for the purpose of getting the viewpoint °t different examiners with respect to the practices and procedures "the respective Federal Reserve banks. Mr. McCabe suggested that it would be extremely helpful whene/e1 'a new Chairman and iCederal Reserve Agent is selected to send him 13' letter advising of the services that are available to him in matters of this kind. It would also be helpful, he said, if the letter could °Iitline the Chairman's responsibilities and make such other sugges- tion - as would be helpful in acquainting him with his new duties. Chairman Eccles stated that we would bear this suggestion Thi He also said that the office of Chairman and Federal Reshould be separated and that when further banking lati II was under consideration this would again be suggested. 14% Parker stated that the survey made a year or so ago by tile ' -Jard's examiners of the auditing department of the Federal ReBank of Atlanta had been extremely helpful and he inquired -1" similar surveys were in contemplation for the future. Mr. NI eer replied that they were and pointed out that surveys of the 41141-t'7,, examination and fiscal agency departments are made from ti rtle t0 time in connection with the regular examinations of the bttrik Mr. Paulger commented on certain points relating to the inrclItati -°n contained in the reports of examinations of the Federal ii 12/5/39 177,c,r) %....dN11-...) -13- Reserve banks made by the examiners for the Board of Governors, and ellmlnerY of this statement has also been placed in the files. Fol- 1°wine the statement Mr. Curtiss stated that it would be helpful if there could be made available to the board of directors the minor matOf criticism which were discussed by the examiners with the °Perating officers but not made a part of the formal report, and ether Chairmen agreed with this suggestion. Mr. Young stated that the report of examination apparently c°11818t8 of three parts: (1) the formal report, (2) matters taken 41) with the officers, and (3) a confidential section which is sent (3111Y to the Board of Governors and is not made available to the He said the formal report was very useful to the direc- tore, tlitit the memorandum of criticized matters for the officers wEts 11 wise way of handling minor matters with the officers although it as of the 'us understanding that it was the practice of the President New York bank to discuss the memorandum with the board of ectn -Iss, that he personally had taken the very firm position that t ere should be nothing which the Board of Governors knew about the 4deral Reserve Bank of New York which he as Chairman of the bank 17" not entitled to know, and that he desired to emphasize that as- .11. Of the matter at this time. The point raised by Mr. Young was discussed, and he explained httt he, uno objection to the procedure now being followed but felt the ci rs should have the same information about the bank as is 1523 12/5/39 -14- alvailable to the Board of Governors. Inquiry was made as to whether it was the present practice of the examiners to discuss the confidential section of the report with the hoard of directors or the Chairman and Mr. Paulger replied in the negative. in the Of the It was pointed out, however, that any information contained confidential sectiOn of the report was brought to the attention board of directors of the bank by letter or otherwise whenever it involved a matter which the Board felt the directors should know abowt. Mr. Ransom said that a procedure that could be followed would ba for the examiner to sit down with the Chairman or Deputy Chairman 'd discuss with him the information which the examiner proposed to Pit in the confidential section of the report. Mir. Eccles stated that the suggestions made during the disSsi would be considered by the Board. Toward the end of the discussion of this matter Mr. Young left the meeting. Mr. Morrill stated that Mr. Davis had gone to Chicago to atterld e meeting of the American Farm Bureau Federation where he would recei ve a special award in recognition of his contribution to agrielatur, that he would discuss with the Chairmen tomorrow the topic or taetaber bank and other public relations activities of the Federal leser '4ee banks, and that he had arranged to present to the Chairmen tociEty transcriots of two of the broadcasts which were being prepared 1524 12/5/39 -15- by the Federal Reserve Bank of Minneapolis as part of a series of thi,.t._ .,en 4u programs dealing with the activities of the Federal Reserve Batik which are being presented over station ItiCCO in Minneapolis. The firSt recording, Mr. Morrill said, related to the facilities of the .hderal Reserve banks for transferring funds by telegraph and the seeolid to the retirement of unfit currency. The two recordings were 1311esented, after which the meeting recessed with the understanding that it Would reconvene again tomorrow morning at 10:00 a.m. 1 : I Secrete . Chairman.