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504 A meeting of the Federal Reserve Board was held in Washingtook on Thursday, February 21, 1935, at 11:45 a. m. ?RESENT: Mr. Mr. Mr. Mr. Mr. Eccles, Governor Thomas, Vice Governor Hamlin Miller James Mr. Morrill, Secretary Mr. Betheal Assistant Secretary Mr. Carpenter, Assistant Secretary The minutes of the meetings of the Federal Reserve Board 41°1 on February 4, 5, 6, 7, 11, 13, 14 and 15, 1935, were approved. The minutes of the meeting of the Federal Reserve Board with the Federal Open Market Committee held on February 5, 1935, were a pproved. The minutes of the meeting of the Federal Reserve Board nth the Governors of Federal reserve banks held on February 6, 1935, wer'a approved. The minutes of the meeting of the Executive Committee of the 441 ' 111 Reserve Board held on February 12, 1935, were approved and the actions recorded therein were ratified unanimously. The Board then acted upon the following matters: Telegram to Mr. Wood, Chairman of the Federal Reserve Bank Or St, Lou,s, reading as follows: "Federal Reserve Board today approved for your bank reulecount rate of 4% on advances to individuals, partnerships °I' corporations on the promissory notes of such individuals, Partnerships or corporations secured by direct obligations (If the United States, under the last paragraph of section 505 2/21/ 55 -2- "13 of the Federal Reserve Act as amended, effective February 25.0 Approved. Telegrams dated February 20, from Mr. Curtiss, Chairman of the Federal Reserve Bank of Boston, and February 21, 1935, from Mr. 1°11ng, Secretary of the Federal Reserve Bank of Chicago, both advisthat, at meetings of the boards of directors on the dates stated, 11° changes were made in the banks' existing schedules of rates of d iscount and purchase. Without objection, noted with approval. Memorandum dated February 16, 1935, from Mr. Paulger, Chief c)f the Division of Examinations, recommending the transfer of Mr. Ge°rge Ringen, an Assistant Federal Reserve Examiner, from the road to the office force, and that his headquarters be changed from St. Louts, Missouri, to Washington, D. C., effective as of February 16, 195 with no change in his present salary of !4 4,500 per annum. Annraved. Letter to Mr. Fletcher, Acting Federal Reserve Agent at the Peci"al Reserve Bank of Cleveland, reading as follows: "The Federal Reserve Board has received your letter of -ruary 14, 1935, and apnroves the designation, effective hlarch 1, 1935, of Mr. Clyde Harrell, a clerk in the audit de1P-rtment of the Cincinnati branch of the Federal Reserve Bank 17! Cleveland, as Acting Assistant Federal Reserve Agent at the ranch, to take the place of Mr. R. G. Johnson who has been apD°inted Assistant Cashier of your Cincinnati branch, effective March 1. "As previously stated, section 16 of the Federal Reserve A e+ renuires that all Federal reserve notes and all gold cer°-ficates and lawful money issued to or deposited with any 506 2/21/35 -5- "Federal reserve agent shall be held for such agent in the joint custody of himself and the Federal reserve bank to which he is accredited. In view of this provision of law, the Federal Reserve Board feels that a representative of a Federal reserve agent participating in such joint custody should be responsible to the Federal reserve agent and indeoendent of the Federal reserve bank in so far as is consistent with the practical situation, and, therefore, before the designation referred to above becomes effective, Mr. Harrell should resign his position as clerk in the audit department of your Cincinnati branch. However, during such periods as Mr. Harrell is not engaged with his duties as Acting Assistant Federal Reserve Agent, he may be detailed by the Federal reserve agent to perform such functions in the audit department of the branch as the agent may consider advisable. It is understood from your letter that this arrangement is to be followed in connection With the designation of Mr. Harrell. "Mr. Harrell should execute the usual form of oath of office and a surety bond in the amount of 50,0001 and he Should not enter upon the performance of his duties as Acting Assistant Federal Reserve Agent until you have received advice of the Board's approval of the bond. Before the bond is forwarded to the Board for approval, it should be examined by Your counsel to determine whether its execution complies fully With the rules printed on the reverse side of form of bond 182." Ap7roved. Letter to Mr. Curtiss, Chairman of the Federal Reserve Bank °I' Boston, reading as follows: "Receipt is acknowledged of your letter of February 16, 1955, advising that because of the illness of Mr. Thomas M. Steele, member of the Federal Advisory Council representing the First Federal Reserve District, the executive committee of Your bank has selected Mr. Thomas P. Beal, President of the Second National Bank of Boston, Massachusetts, as alternate to represent the First District at the meeting of the Council to be held on Febrwry 1D-20, 1935. "In connection with the selection of Mr. Beal as alternate for Mr. Steele, your attention is directed to the Board's circular letter of March 25, 1925 (X-4296), a copy of which is attached." Approved. Letter to Mr. Strater, Secretary of the Federal Reserve Bank 507 2/21/35 -4- of Cleveland, reading as fo1lo7s: "The Federal Reserve Board has received your telegram of February 18, 1935, and apnraves the appointment of Mr. Hugh L. Gaddis as the fifth member of the Industrial Advisory Committee for the Fourth Federal Reserve District for a term of one year from March 1, 1935." Approved. Letter to Mr. Clark, Assistant Federal Reserve Agent at the 4dere1 Reserve Bank of Atlanta, reading as follows: "Reference is made to your letter of January 28, 1935, inclosing the application of The First National Bnnk of Cookeville, Cookeville, Tennessee, for 24 additional shares of stock of the Federal Reserve Rank of Atlanta. "It is noted that, while the Board on October 9, 1934, approved an application of the subject bank for 30 additional Shares of Federal Reserve bank stock, the bank reduced its surplus by g10,000 before the additional shares were issued, and that, on the basis of the bank's present capital and surplus, it is entitled to 24 instead of 30 additional shares of Federal Reserve bank stock. For this reason you have submitted a new aPplication for 24 shares to take the place of the approved anplication for 30 shares. "In the circumstances, you are authorized to issue 24 Shares of Federal Reserve bank stock under the application approved on October 9, 1934, instead of 30 shares as shown in that application. "In future instances of this kind, where a member bank reduces its capita' and surplus below that shown in its application for Federal Reserve bank stock as approved by the Board, it is suggested that you issue an appropriate number of shares of Federal Reserve bank stock based upon its reduced capital and surnlus and advise the Board of the circumstances." Approved. Letter to Mr. Clark, Assistant Federal Reserve Agent at the 1."1 Reserve Bank of Atlanta, reading as follows: "Receint is acknowledged of your letter of February 12 l'egarding the affiliates of the Columbus Bank & Trust Company, T.+ 508 2/21/F5 re' 0.• -5_ "Columbus, Georgia. In view of the fact that the affiliate relationshins in nuestion have been terminated, the Board cencurs in vour opinion that no further corrective action is reauired." Approved. Letter to Mr. Pone McAdams, Vice President and Cashier of the First National Bank, Louisville, Kentucky, reading as follows: "This refers to your letter dated January 18, 1935 regarding the euestion whether a loan of money by the First National Bank, Louisville, Kentucky, to 8 holder of the bank's certificate of deposit, unon the security of such certificate of deposit, constitutes a violation of section 19 of the Federal Reserve Act and of the Board's Regulation 0 nrohibiting the nayment of time denosits before maturity. "In a previous letter dated November 3, 1934, the bank requested advice concerning a proposed loan to a holder of a certificate of denosit who wished to borrow the amount of her time deposit in order to nurchase an automobile, and who desired to give the bank her note secured by the certificate of deposit and Payable at the date the certificate of ele'losit was payable. "In answer to such inquiry, the Board stated in its letter dated November P, 1934 that the making of a loan to the owner of a time deposit by a member bank for the purpose of evading the Prohibition upon the payment of a time denosit before its maturity will, to the extent of such loan, be deemed to be a nayment of such denosit in violation of the Board's Regulation Q. The Board also stated that the nuestion whether a loan made by a member bank to the owner of a time denosit constitutes a violation of the prohibition depends upon whether the loan was made in good faith or for the purpose of evading such prohibition, and that the Board feels that such a nuestion should be considered by a member bank at the time such transaction is Dronosed and should be determined by such bank in the exercise of its best judgment and in the light of the provisions of the lew and the Board's regulation. With reference to the bank's licuiry, the Board stated that the making of the nronesed loan in the circunstances stated would probably involve an evasion of th Prohibition upon the nayment of the time deposit before its maturity. "In your letter dated January 18, 1935, you state that in the case covered by the nrevious innuirv, no agreement had been entered into between the bank and the holder of the certificate Of deposit at the time the certificate was purchased that the I gri 509 2/21/35 -6- "bank would make a loan on the certificate, and that no previous understanding of any kind was had with the holder of the certificate that the bank would make a loan upon such certificate. You also recuest a definite answer to the cuestion Whether or not it is lawful for the bank to make loons to the owners of its certificates of denosit. "The Federal Reserve Board feels that it should not attemnt to furnish a definite answer to such cuestion in view of the large number of circumstances which may affect the determination of the cuestion in any particular case. However, the Board feels that it may properly state that a loan to the owner Of a time deposit secured by a certificate of deposit may constitute an evasion of the prohibition of payment of a time deposit before its maturity, even though no agreement, arrangement, or understanding was made between the bank and the holder of the certificate of deposit at the time the certificate was nurchased that the bank would make a loan upon the certificate. The fact that a customer requests the payment of a time certificate of denosit before its maturity and, upon finding that such Payment cannot be obtained, recuests that a loan be made on the security of the certificate, is ordinarily a stronr indication that the purpose of the borrowing or loan, if consummated, would be to circumvent the prohibition against the payment of a time deposit before its maturity. That such would be the PlirPose is even more clearly indicated if the loan as thus pronosed is to mature on the date of the maturity of the certificate. "Although circumstances may arise in which the making of a loan by a bank unon the security of a certificate of deposit would be in good faith and not for the purnose of evading the Prohibition noon the Payment of time denosits before maturity, it is the opinion of the Federal Reserve Board that such circumstances are rare. The Board feels that the ouestion whether the making of a loan upon the security of a certificate of dePosit is for the purnose of evading the prohibition upon the payment, of time deposits before maturity should be left to the judgment of the member bank and also feels that, in cases where there is any considerable doubt in the matter, the safest course for the bank to follow in deciding this question is to refrain from makino. such loans, in view of the fact that the bank must be nrenared to show clearly that such transactions " are not in contravention of the applicable nravisions of laws. Annroved. Letter to Honorable William Lemke, House of Representatives, 510 2/21/F,5 reading as follows: "Reference is made to your letter of February 5 regarding the annlicat4 on of Mr. Fred Timmer, President of the Fargo Jewelry Manufacturing Co., Fargo, North Dakota, for a loan from the Federal Reserve Bank of Minnearolis under the terms of Section 1724) of the Federal Reserve Act. "Tt annears from the corresnondence which you submitted to us with your letter, and from information furnished by the Federal Reserve Bank of ninnearolis, that ?Jr. Timmer made annlicetion for a loan in the amount of 'Z,000, to be divided into two parts, 1,500 to be secured by the company's machinery and fixtures, and :1 1,500 to be secured by school contracts. The comrany planned to repay the loan at the rate of 20 percent a Year, which would give the loan five years to run. "The machinery and fixtures, according to Mr. Wimmer's own statement, are valued at, 1,460.60, which is somewhat less than the amount for which they are offered as security, and their sale value in case of foreclosure would presumably be still less than their book value. The contracts which Mr. Wimmer offered as further security appear to be orders signed by students and their teechers. In the case of both the enuipment and the contracts, 1-ho value of the security would largely disannear if business operations were discontinued. The hone of repayment 1"uld, therefore, have to depend almost wholly on the maintenance of nrofitablo operations. "Mr. Wimmer's record, however, gives no assurance of his ability to carry on the business successfully over a period of Years, and to repay the loan from Profits. His past management has not been successful, and his recent records show no profit. Furthermore, it is to be noted from his letter of January 12 tnat he contemplated having to make further borrowings on the same basis next fall. In View of these doubtful rrosnects, and leaving aside the ouestion whether the Federal Reserve bank was amPly orotected, it does not seem that Mr. Timmer would improve his Position by the assumntion of an obligation which would more Probably increase his burdens than lighten them. "The fact that Mr. Wimmer's company is a comparatively small one does not annear to have created any Prejudice against his application. The Federal Reserve Bank of Minnearolis has T"e a number of other loans of even smaller amount under the -cerms of Section lFb of the Federal Reserve Act. "In accordance with your renuest, we return herewith the inclosures which accomnenied your letter of Februrry 5." Annroved. 511 2/21/55 -8Letter to Mr. Fred T. Rombach, Vice President of the Watson- Table & Furniture Company, Tatsontorn, Pennsylvania, reading as follows: "Reference is made to your letter of December 31, 1934, to the Secretary of the Treasury, regarding the Policy of the Federal Reserve banks in respect to applications submitted for loans under authority of Section MI of the Federal Reserve Act and referring particularly to the industrial loan application filed by your company. "We are informed by the Federal Reserve Bank of Philadelphia, in resnonse to our reouest for information, that it did not feel that the loan could be made without additional collateral, unless subordination of annroximately $9,300 of existing indebtedness could be procured. Efforts to effect this subordination annear to have been unsuccessful. Apparently no Other satisfactory collateral was available, and to nermit more than one-third of the new lom to be used to licuidate existing indebtedness seemed unjustifiable. "We regret that unoualified approval could not be given to Your application, but since it received careful and repeated consideration by the Industrial Advisory Committee and the Federal Reserve Bank of Philadelphia, and inasmuch as they concurred in the conclusion that it could not be approved unless the aforementioned condition was met, there appears to be no basis for further action by the Federal Reserve Board in the matter. "It is noted that you speak of the unfavorable action on Your application as tyPical of the acf ion taken by the Federal Reserve banks in general toward loans applied for under the terms of Section 13b of the Federal Reserve Act. It may be Pointed out, however, that the law authorizes the Federal Reserve banks to make loans only on a reasonable and sound basis, and that the Federal Reserve bank has no choice but to disanProve those loans which in its judgment fail to satisfy the reruirements of the law." Anproved. Letter to Mr. Curtiss, Federal Reserve Agent at the Federal Rese.p.- "e Bank of Boston, prepared in accordance with the action taken 4't the meeting of the Board on February 13, 1935, and reading as follows: 512 2/21/35 -9- "Consideration has been given to the application of Mr. Louis Curtis under the provisions of section 32 of the Banking Act of 1933 for a permit to serve as director of The Merchants National Bank of Boston and as trustee of Century Shares Trust, both of Boston, Massachusetts. "It appears from the information which has been submitted that Century Shares Trust is a so-called 'investment trust', organized March 1, 1928, that its assets are invested principally in the stock of banks and insurance companies, and that it has never participated in any way in the underwriting, issue, or distribution of securities other than its own. It appears that purchases and sales of securities in its portfolio represented the following percentages of its total assets for each of the following years: Year Purchases Sales 1929 121.00 52.76 1930 13.85 17.85 1931 4.44 4.55 1932 5.65 9.32 1933 9.67 5.36 "It appears further that the shares of the Trust are sold and redeemed at the then liquidating value of the underlying securities when such Shares are offered or called for by the public. However, it appears that the Trust does not sell its shares directly to the public but, prior to the organization of Brown Harriman & Co., Incorporated, sold units consisting of one Participating Share and one Ordinary Share at their then liquidating value to the firm of Brown Brothers Harriman & Co., which retained ownership of the Ordinary Shares and offered the Participating Shares to the public. The Board is without information as to Whether the stock is now sold by Brown Brothers Harriman & Co. or by the new corporation, Brown Harriman & Co., Incorporated. "It annears from the Trustees' reports that the shares of the Trust sold and redeemed, respectively, during the years 1931 to 1933, inclusive, constituted the following percentages of the total shares outstanding: Year Sold Redeemed 1931 7.68 3.26 1932 6.88 9.11 1933 2.99 9.94. "Tn the light of the above information, the Board believes that Century Shares Trust should not be deemed to be 'engaged 1)rimarily in the business of purchasing, selling, or negotiating Becuritiest within the meaning of section 32, and that, therefore, a Permit covering the relationships described in the first paragl'aph of this letter is unnecessary. 513 2/21/35 -10- "It will be appreciated if you will advise Mr. Curtis accordingI;y." Approved. Letter to Mr. Clark, Assistant Federal Reserve Agent at the Federal Reserve Bank of Atlanta, reading as follows: "Receipt is acknowledged of your letter of February 4, 1935, with reference to the possible applicability of section 32 of the Banking Act of 1935 and/or section SA of the Clayton Act to Mr. John Allen Jones, a director of The National Bank of Opelika, Opelika, Alabama. "It appears from your letter that a Mr. Breedlove, of ODelika l is a telegraph onerator who has access to a leased wire controlled by Fenner & Beane, New Orleans, Louisiana. Mr. Breedlove furnishes business men in Opelika with quotations obtained from this leased wire, and also places orders for them with Fenner & Beane for commodities and securities. In order to protect Fenner & Beane from loss resulting from orders placed with them by Mr. Breedlove, Mr. Jones has entered into an arrangement with Mr. Breedlove which is termed a 'nominal partnership', solely for the accommodation of Mr. Breedlove. It appears that the profits received by this 'partnership? from the orders referred to above do not average more than i2.5 per month. It further appears that any loans which ma7 be made on stock or bond collateral as a result of such orders are made by Fenner & Beane. "On the basis of the above information, the Federal Reserve Board sees no reason to differ with the conclusion reached by you and your counsel that neither section 32 of the Banking Act of 1035 nor section SA of the Clayton Antitrust Act are applicable to Yr. Jones. It will be anpreciated if You will advise Mr. Jones accordingly." Apnroved. Letter to Mr. Case, Federal Reserve Agent at the Federal Resere Bank of New York, reading as follows: "On May 8, 1934 the Board granted to Mr. James H. Perkins a permit under the provisions of section 32 of the Banking Act of 1933 to serve at the same time as director and officer of The National City Bank of New York, and as director of 514 2/21135 -11- "Discount Corloration of New York, both of New York, New York. Subseeuently, you recommended that the permit be amended so as to cover also Mr. Perkins' service as officer and director of City Bank Farmers Trust Company, New York, New York, in view of the fact that that comnany had since become n member of the Federal Reserve System, thus making section 32 applicable to Mr. Perkins' services to it. "In view of the fact that on January 17, 1935 the Board granted a permit to Mr. Perkins under the provisions of the Clayton Antitrust Act to serve the national bank and the trust company named above and International Banking Cornoration, Bridgeport, Connecticut, it annears that the permit issued to him under section 32 may properly be amended pursuant to your recommendations, and there is therefore inclosed the original of such amended nermit for transmittal to Mr. Perkins, and conies thereof for transmittal to the institutions involved and a cony for your files." Anproved. Letter to r. Case, Federal Reserve Agent at the Federal Reserve Bank of New York, reading as follows: "On May 8, 1934 the Board granted to Mr. Gordon S. Rentschler a nermit under the nrovisions of section 32 of the Banking Act of 1935 to serve at the same time as director and Officer of The National City Bank of New York and as director of Discount Corporation of New York, both of New York, New York. Subsemently, you recommended that the Permit be amended so as to cover also Mr. Rentschler's service as director of City Bank Farmers Trust Company, New York, New York, in View of the fact that that comnany had since become a member of the Federal Reserve System, thus making section 32 applicable to Mr. Rentschler's services to it. "In view of the fact that on January 17, 1935 the Board granted a permit to Mr. Rentschler under the nrovisions of the Clayton Antitrust Act to serve the national bank and the trust company named above and International Banking Cornoratien, Bridgenort, Connecticut, it appears that the Permit issued to him under section 32 may properly be amended pursuant to Your recommendations, and there is therefore inclosed the Original of such amended permit for transmittal to Mr. Rent, ?ehler, and conies thereof for transmittal to the institutions Involved and a cony for your files." Anproved. 515 2/21/55 -12Letter to Mr. John F. Gouldman, Jr., The Planters National Bank in Fredericksburg, Fredericksburg, Virginia, reading as follors: "The Fderal Reserve Board understands that you are serving as a director of The Planters National Bank in Fredericksburg, Fredericksburg, Virginia, as officer and director of The Farmers and Merchants State Bank, Fredericksburg, Virginia, and as president of the Bank of Lancaster, Kilmarnock, Virginia, apparently in violation of the nrovisions of section 8A of the Clayton Antitrust Act. ”The Board has been advised that the Federal Reserve Agent at the Federal Reserve Bank of Richmond has furnished YOU with the necessary forms and information for the making Of an application for a permit under the provisions of that Act covering such services, but that such an application has not been nronerly completed and filed with the Federal Reserve Agent as reouired by Regulation L of the Federal Reserve Board, which deals with the provisions of that Act. "It is assumed that you do not desire or intend to continue to serve in violation of law, and this letter is therefore being addressed to you in order to give you an opportunitY of taking such stens as are necessary in the premises. Please advise the Federal Reserve Agent at. the Federal Reserve Bank of Richmond promptly as to the stens which you will take in order to comply with the provisions of the Clayton Act." Approved. Letter to Mr. Hoxton, Federal Reserve Agent at the Federal ileserlre Bank of Richmond, prepared in accordance with the action taken at the meeting of the Board on February 13, 1935, and reading as follows: "The Board has given consideration to the apnlications °f Messrs. H. P. Jones and Carl A. Jones, Bristol, Virginia, for Permission under the nrovisions of the Clayton Act to .,?rve at the same time as directors and/or officers of The !lrst National Bank in Bristol, Bristol, Tennessee, and Washington Trust and Savings Bank, Bristol, Virginia; and, uoon the basis of the information before it, feels that the issuance °f the permits annlied for would be incompatible with the 516 2/21/35 -13- "public interest. You are reouested to advise the annlicants of the Board's nosition in the matter, unless there are pertinent facts which were not sill-mated with the applications and which you feel should be given consideration. "Please inform the Messrs. Jones that the Board's action Upon their applications was based upon the fact that the banks apnear to he engaged in the same class or classes of business and so located as to be in a position to compete substantially. It appears that it is the policy of the Congress, as declared in the Clayton Act to terminate interlocking relationshins between banking institutions of certain classes which are in substantial competition, annarently because the Congress felt that such relationships might tend to result in a substantial lessening of competition and a restriction of credit. Therefore, the Board does not feel that it may grant these applications since no other facts have been brought to its attention which would make it compatible with the public interest to issue the nermits. In this connection reference is made to the Board's letter of Januar7 9, 1935 (X-9082). "In communicating with the applicants, please advise them that, in accordance with Section V (g) of Regulation L, consideration will be given to any additional facts or arguments not appearing in their annlications and accompanying forms which they feel should be brought to the Board's attention. In this connection, Please advise the Board nromptly aS to whether the Messrs. Jones desire to submit any additional data and, if not, as to what steps they propose to take in order to comply with the provisions of the Clayton Act. "A copy of this letter is being sent to the Assistant Federal Reserve Agent at Atlanta for his information and records." Approved. Letter to Mr. Hoxton, Federal Reserve Agent at the Federal Reserve Flank of Richmond, prepared in accordance with the action taken at the meeting of the Board on February 13, 195, and readas follows: "The Board has given consideration to the application of Mr. T. N. McAnge, Jr., Bristol, Tennessee, for permission Under the provisions of the Clayton Act to serve at the same 517 2/21/35 -14- "time as director of The First National Bank in Bristol, Bristol, Tennessee, and as director of The Dominion National Bank of Bristol, Bristol, Virginia; and, upon the basis of the information before it, feels that the issuance of the Permit applied for would be incompatible with the nublic interest. You are requested to advise the applicant of the Board's position in the matter, unless there are nertinent facts which were not adhmitted with the annlication and Which you feel should be given consideration. "Please inform Mr. McAnge that the Board's action upon his application was based upon the fact that the banks appear to be engaged in the same class or classes of business and so located as to be in a position to compete substantially. It appears that it is the policy of the Congress, as declared in the Clayton Act to terminate interlocking relationshins between banking institutions of certain classes which are in substantial cornetition, apparently because the Congress felt that such relationshins might tend to result in a substantial lesseninq: of competition and restriction of credit. Therefore, the Board does not feel that it may grant this application since no other facts have been brought to its attention Which would make it compatible with the public interest to issue the permit. In this connection reference is made to the Board's letter of January 9, 1935 (X-9182). "In communicating with the aonlicant, nlease advise him that, in accordance with Section V (g) of Regulation L, consideration rill be given to any additional facts or arguments not annearing in hts annlication and accompanying forms which he feels should be brought to the Board's attention. In this connection, nlerlle advise the Board promptly as to whether Mr. McAnge desires to submit any additional data and, if not, as to what stens he nronoses to take in order to comply with the Provisions of the Clayton Act. "A cony of this letter is being sent to the Assistant Federal Reserve Agent at Atlanta for his information and records." Anproved. Letter to Mr. Stevens, Federal Reserve Agent at the FedReserve Bank of Chicago, prepared in accordance with the acti0r1 taken at the meeting of the Board on February 1935, and 11"-aing as follows: "Reference is made to the Clayton Act application of Mr. e. o' 518 2/91/35 -15- "Stenhen B. Monroe, Kalamazoo, Michigan, to serve at the same time as director of American Nation--1 Bank of Kalamazoo and Kalamazoo Industrial Bank, both of Kalamazoo, Michigan, which was not approved 177. the Board as indicated in its letter of September 14, 1934, to you; and to the application of Mr. Albert E. Kettle, also of Kalamazoo, Michigan, to serve at the same time as director of The First National Bank and Trust Company of Kalamazoo and Kalamazoo Industrial Bank, Which was not approved by the Board as indicated in its letter of September 22, 1954, to you; and to subsequent correspondence with respect to these applications. "The Board has reconsidered the applications of Messrs. Monroe and Kettle and, in accordance with the policy set forth in its letter of January 9, 1935, (X-908?), has granted permits covering their respective services to the above named banks for the period ending January 14, 1936. There are inclosed the originals and conies of the permits for transmittal by you to the applicants and the banks involved and conies for Your files. "When the permits are sent to the applicants and conies thereof to the banks involved, please advise them that the permits have been issued so as to expire at the close of Januarr 14, 1936, as there is now pending before the Congress proposed legislation for the Purnose of clarifying and otherwise amending the nravisions of the Clayton Act relating to interlocking bank directorates." Approved. Letter to Mr. Wood, Federal Reserve Aaent at the Federal Re8erVe Bank of St. Louis, reading as follows: "There are inclosed the original and copies of the Clayton Act nermit issued to Mr. G. W. Brichler, East St. Louis, Illinois, covering his service as director of First National Bank at East St. Louis, East St. Louis, Illinois, and director and officer of The First National Bank of Lebanon, Lebanon, Illjnoj "In considering this application it was noted that the ?-Pnlicant is serving as President and director of State Savings and Loan Association which is described as a building and loan association. In reply to ouestion 13 on F.R.B. Form 94) with respect to whether any organization served by the aPPlicant makes loans secured by stock or bond collateral, the applicant states: 'Yes. Roth banks listed do a commercial bankino,. business 519 2/21/35 -16- "'and the State Savings and Loan Association does a regular building and loan business'. "It seems probable that State Savings and Loan Associetion does not make loans secured by stock or bond collateral Within the meaning of section 8k of the Clayton Act, and as You, of course, know loans made to its own shareholders on the security of its own shares, as a part of the general plan under which building and loan associations usually operate are not the type of loans 'secured by stock or bond collateral' referred to in section BA. In this connection reference is made to the Board's letter of September 11, 1933 :X-7584). "If you find that the provisions of section 8A are not applicable to Mr. Brichler's service to State Savings and Loan Association, please transmit the inclosed permit to him and copies thereof to the banks involved, retaining a copy for 3.7our files, and advise the applicant that the permit has been issued so as to expire at the close of January 14, 1936, as there is now pending before the Congress pro:)osed legislation for the purpose of clarifying and otherwise amending the provisions of the Clayton Act relating to interlocking bank directorates. However, if you find thLt section 8A is applicable Brichler's service to State Savings and Loan Associa' 10n, please advise the Board fully and return the inclosed permit to the Board." Approved. Letters to applicants for permits under the Clayton Act 4(4-1-4 "ng respectively of the issuance by the Board of permits as rollows: !I% George J. Bassett, to serve at the same time as a director of The New Haven Bank, National Banking Association, New en, Connecticut, and as a director of The Morris Plan ,ank, New Haven, Connecticut, for the period ending January J.4, 1936. r Mr, A ."-'* O. Johnson, to serve at the same time as a director and officer of the First National Bank at East St. Louis, St. Louis, Illinois, as a director and officer of The National Bank of Lebanon, Lebanon, Illinois, and as a rector and officer of the Illinois State Trust Company, East at Louis, Illinois, for the period ending January 14, 1956. Approved. 520 2/21/35 -17- There was then nresented the following annlicaton for a Chan-e in stock of a Federal reserve bank: 1122 ,11211tion for ORIGINAL Stock: Shares The FirstTonnl Bank in Glidden, Glidden, IoTa 36 Annroved. Thereunon the meeting adjourned. APProved: 36