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Minutes for

To:

Members of the Board

From:

Office Of the Secretary

July 11, 1963

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. Mills
Gov. Robertson
Gov. Balderston
Gov. Shepardson
Gov. King
Gov. Mitchell

Minutes of the Board of Governors of the Federal Reserve
System on Thursday, July 11, 1963.

The Board met in the Board

Room at 10:00 a.m.
PRESENT:

Mr.
Mr.
Mr.
Mr.
Mr.

Martin, Chairman
Balderston, Vice Chairman
Mills
Robertson
Shepardson
Mr. Kenyon, Assistant Secretary
Mr. Fauver, Assistant to the Board
Mr. Farrell, Director, Division of Bank
Operations
Mr. Solomon, Director, Division of
Examinations
Mr. Johnson, Director, Division of
Personnel Administration
Mr. Connell, Controller
Mr. Hexter, Assistant General Counsel
Mr. Koch, Associate Director, Division of
Research and Statistics
Mr. Daniels, Assistant Director, Division
of Bank Operations
Mr. Masters, Associate Director, Division
of Examinations
Mr. Thompson, Assistant Director, Division
of Examinations
Mr. Sprecher, Assistant Director, Division
of Personnel Administration
Mr. Spencer, General Assistant, Office of
the Secretary
Mr. Bakke, Senior Attorney, Legal Division
Mr. McClintock, Supervisory Review Examiner,
Division of Examinations

Circulated or distributed items.

The following items, copies

of which are attached to these minutes under the respective item numbers
indicated, were approved unanimously:
Item No.
Letter to Rhode Island Hospital Trust Company,
Providence, Rhode Island, approving the establishment of a branch on North Main Street.

1

7/11/63
Item No.
Letter to The Elyria Savings & Trust Company,
Elyria, Ohio, approving an extension of time
to establish a branch on Cleveland-Elyria Road,
North Ridgevill branch operations conducted
at 7077 Avon-Belden Road to be discontinued
simultaneously with the establishment of the
new branch.

2

Letter to Union Trust Company of Maryland,
Baltimore, Maryland, approving the establishment of a branch at Belcamp.
Letter to Bankers Dispatch Corporation, Chicago,
Illinois, granting a determination exempting it
from all holding company affiliate requirements
except those contained in section 23A of the
Federal Reserve Act; letter to the Federal Reserve
Bank of Chicago transmitting the letter to Bankers
Dispatch Corporation and commenting on the situation.

4-5

Letter to all Federal Reserve Banks regarding the
handling of applications from State member banks
for permission to exercise trust powers.
Letter to the Office of the Comptroller of the Currency
with respect to annual leave accumulated by employees
of the Federal Reserve Issue and Redemption Division.

7

With respect to Item No. 4, Governor Mills commented that the
application of Bankers Dispatch Corporation seemed to involve almost a
borderline case.

It was noted, in discussion, that the last paragraph

of the letter to the Corporation had been drafted in recognition of this
situation and that the transmittal letter to the Federal Reserve Bank of
Chicago (Item No. 5) would call attention to the need for following
developments through periodic review.

-3-

7/11/63

Regarding Item No. 7, the letter to the Office of the Comptroller
of the Currency, as approved, reflected certain changes in the draft
that had been distributed prior to the meeting.
Messrs. Johnson, Connell, Daniels, Masters, Sprecher, Thompson,
and Bakke then withdrew and Mr. Furth, Adviser, Division of International
Finance, entered the room, along with Mr. Dembitz, Associate Adviser,
Division of Research and Statistics.
Report on competitive factors (Baltimore-Pleasantville, Ohio).
There had been distributed a draft of report to the Comptroller of the
Currency on the competitive factors involved in the proposal of The First
National Bank of Baltimore, Baltimore, Ohio, to acquire the assets of
and assume liability to pay deposits made in The Pleasantville Bank,
Pleasantville, Ohio.
The report was approved unanimously for transmittal to the Comptroller, the conclusion therein being stated as follows:
The First National Bank of Baltimore and The Pleasantville
Bank apparently serve primarily their respective small communities,
and the acquisition of Pleasantville Bank by First National would
have no serious adverse effects on competition.
Mr. McClintock then withdrew, and Mr. Partee, Chief, Capital
Markets Section, Division of Research and Statistics, entered the room.
Rates on time deposits.

There had been distributed to the Board

a letter dated June 27, 1963, from the Federal Reserve Bank of New York
regarding provisions of Regulation Q, Payment of Interest on Deposits,
time
relating to the maximum permissible rates of interest payable on

7/11/63
certificates of deposit.

The letter supported the recommendation made

by the Commission on Money and Credit, the Advisory Committee on Banking
to the Comptroller of the Currency, and the President's Committee on
Financial Institutions that Federal authority to regulate interest rates
on time and savings deposits be placed on a standby basis, and it noted
that a bill (S. 1799) to put this recommendation into effect had been
Introduced in the Congress.

The letter stated that the New York Reserve

Bank also looked with favor on the emergence of negotiable time certificates
of deposit and the development of the secondary market in which they were
actively traded.

The Reserve Bank believed that this instrument had

Increased the flexibility of the banking system by providing another
sensitive market mechanism.
The letter from the New York Reserve Bank urged the Board to
increase the present rate ceilings with respect to certain classes of
time deposits, other than savings deposits, in view of the possibility
that short-berm interest rates might rise above levels that had prevailed
for the past two yeara, and because this development might take place
before enactment of possible legislation that would obviate the need
for continuously regulating the maximum rates on time and savings
deposits.

In this respect, it recommended that the maximum rate for

time certificates of deposit having maturities of not less than six
months but less than one year be raised to 3-3/4 per cent from 3-1/2
per cent, the belief being stated that this was the most vulnerable area;

-5-

7/11/63

it accounted for approximately two-thirds of outstanding certificates
of deposit.

The Board was also urged to establish a maximum rate for

time deposits with maturities of not less than 90 days but less than
six months that was in line with market rates.

It was believed that

in this maturity range domestic banks could become most effective in
competition with the Euro-dollar market.

At the present time the 2-1/2

per cent maximum rate for such deposits was not sufficiently high to
enable banks in the United States to hold or attract foreign private
balances or to retard or reverse the growing tendency of corporate treasurers to place dollar funds abroad.

An increase in time deposit rates

here probably would not be fully matched by a related rise in the Eurodollar market, and consequently some restraint on corporate funds going
Into that market should result.

It was suggested, therefore, that the

Board raise the maximum permissible rate on time deposits with maturities
of not less than 90 days but less than six months to at least 3-1/2 per
cent.
Governor Balderston, who had requested that the letter from the
New York Reserve Bank be placed on the agenda for this morning's meeting
for discussion, spoke of his concern as long as a year ago with respect
to the loss of short-term funds through Canada into the Euro-dollar
market.

He said that in February he had given thought to bringing before

the Board a suggestion for changing the ceiling rates for time deposits
with maturities of one year and under, but he had come to the conclusion

-6-

7/11/63

at that time that the development of the secondary market for negotiable
certificates of deposit might provide an alternative answer.

However,

if at any time there should be a change in the discount rate, such a
change might precipitate a loss of negotiable certificates of deposit,
and the major impact of that loss would likely fall first upon the market
for municipal securities and probably upon the mortgage market.

In

short, the response in terms of investment and lending practices might
be one that was not desired.

In his own thinking, Governor Balderston

commented, if there were a change in the discount rate sometime in the
future, there should also be a change in the ceiling rate applicable
to certificates of deposit with maturities from six months to one year.
The New York Reserve Bank had recommended, as of June 27, that the
ceiling be changed to 3-3/4 per cent.

In his view,

4 per

cent might be

more appropriate, particularly in the light of recent market developments.
However, an unanswered question in his mind was whether such a change
would reduce the term of all negotiable certificates of deposit to six
months.

With respect to the maximum rate for time deposits with maturities

of 90 days to six months, the New York Reserve Bank had stated that the
2-1/2 per cent ceiling was unrealistic, a point with which he concurred,
and had suggested that it be raised to 3-1/2 per cent.

Governor Balderston

suggested, however, that some thought might be given to raising the maximum
Permissible rate as high as 3-3/4 or even

4 per

cent.

Alternatives for

U. S. corporate treasurers included 6-month Treasury- bills yielding roughly

-7-

7/11/63

3.30 per cent and Euro-dollar rates that might be running as high as

4

per cent.

Hire-purchase paper in England was yielding 4-1/2 per cent.

Governor Mills expressed an opposite view concerning the proposal,
which he thought could be more harmful than helpful.

He suggested that

it was necessary to consider whether the large commercial banks should
be operating in negotiable certificates of deposit.

The loss of liquidity

incident to going into municipals and mortgages had been encouraged by
this kind of operation.

The banks had been borrowing short and lending

long, contrary to sound banking principles, because they could not cover
the interest paid on the time certificates except by acquiring assets
of long maturity.

If there should be an increase in the Regulation Q

rates, which he thought would be completely wrong policy, that would have
to be a substantial increase, and it would further encourage the practice
of borrowing short and lending long.

If one was thinking in terms of a

monetary and credit policy aimed at the balance of payments problem, an
increase of the permissible rates under Regulation Q might lead to a
weaker rather than a stronger position.

If the ceiling rates were left

at their present levels and the negotiable certificates began to run off,
the question was what the investors in those certificates would do with
the proceeds.

They would not necessarily move them to Canada or into the

Euro-dollar market.

The issuing banks would have less loanable funds

at their disposal, and in the face of that they would tighten their
lending processes.

This would result in a strengthening of interest

,k
)1 .)
Aw )

-8-

7/11/63

rates, out of the banks' awn activities, that would abet the policy
of a stronger interest rate structure.

Further, it was conceivable

that the current investors in time certificates of deposit were also
bank borrowers.

If the money came back to them from the certificates,

it presumably would flow back into the demand deposits of the issuing
banks, at least to some extent.

This would relieve pressure on the

money supply that the tightening of monetary and credit policy would
otherwise exert and allay some of the concern that monetary policy would
be economically damaging through contracting the money supply.

Or, if

holders of the certificates would otherwise have felt compelled to
borrow at their banks ut a higher cost, they could be relieved of that
necessity by having funds at their disposal that had been placed in
the time certificates.

As to the issuing banks, if they could be con-

ceived of as managing their affairs with any discretion, they must have
staggered within some reason the paper held against the time certificates.
This would mean a correlated runoff, and they Should not be faced with
severe difficulties.

If in some individual cases banks should be con-

fronted with problems through their operations in negotiable time
certificates, that would reflect poor management, and banks of that
type should be encouraged to drop out of this field.

In his opinion,

in fact, the banks had no business in this field to begin with, and
this would be a favorable opportunity to wedge them out.

None of them

seemed to have made any money; the bulk, even last year, showed no net

7/11/63

-9-

operating profits, and now they would have the cost of higher interest
expense.

They only got an increase in total deposits, for whatever

gain that might be in terms of pride and power to attract business.
In addition, if the ceiling rates were raised, one would have to think
beyond the field of banking to the ramifications of such action in the
mortgage loan field, where there was a substantial flow of mortgage funds
and every reasonable encouragement to pull them down.

For the Federal

Reserve to encourage higher rates on time money would not be in the
public interest, as he saw it.

At any rate, this was nothing that would

be acted upon at this meeting or in the very near future, he judged.
Chairman Martin said that the matter was not up for action today,
but it was something that ought to be studied because it had a bearing
on the over-all problem.
There followed comments by several members of the staff, at the
invitation of the Board, on various aspects of the problem under discussion,
and it was suggested by Chairman Martin that the principal comments be
summarized in memorandum farm so that they might be available to the
members of the Board for further study.
Secretary's Note: Memoranda from Messrs. Furth,
Dembitz, and Partee were distributed to the Board
members under date of July 12, 1963.
The discussion concluded with general comments and questions by
members of the Board based to a considerable extent on the points raised
by the members of the staff who had spoken.
The meeting then adjourned.

-10-

7/11/63

Secretary's Note: Pursuant to recommendations contained in memoranda from appropriate
individuals concerned, Governor Shepardson
today approved on behalf of the Board the
following actions relating to the Board's
staff:
Appointments
ary, with
Eva L. Jarvis as Minutes Clerk, Office of the Secret
of
date
the
ive
,
effect
$3,820
of
rate
the
basic annual salary at
entrance upon duty.
nel AdministraMary Ann Monaghan as Clerk-Typist, Division of Person
effective the
tion, with basic annual salary at the rate of $3,820,
date of entrance upon duty.
ve Services,
Wilbert J. Hart as Messenger, Division of Administrati
of
with basic annual salary at the rate of $3,245, effective date
entrance upon duty.
Acceptance of resignations
ive July 13,
Rufus S. Hill, Jr., Attorney, Legal Division, effect
1963.
ch and
Norma Jean Hicks, Clerk-Stenographer, Division of Resear
Statistics, effective July 26, 1963.
Statistics,
Bettie P. Tuttle, Secretary, Division of Research and
effective July 19, 1963.
l Finance, effecFlorence S. Doane, Clerk, Division of Internationa
tive July 12, 1963.

Assistant Secret

,?-2f
Item No. 1

BOARD OF GOVERNORS
mitiott**,

7/11/63

OF THE

44114°0
V)1,0f.

FEDERAL RESERVE SYSTEM

N

WASHINGTON 25, 0. C.
ADDRESS OFFICIAL CORRESPONDENCE
TO THE HOARD

0.4 wAl• „tft
04***
July 11, 1963

Board of Directors,
Rhode Island Hospital Trust Company,
Providence, Rhode Island.
Gentlemen:
The Board of Governors of the Federal Reserve
System approves the establishment by Rhode Island
Hospital Trust Company, Providence, Rhode Island, of a
branch on North Main Street in the Lippitt Hill section
of Providence, Rhode Island, provided the branch is established within two years from the date of this letter.
Very truly yours,

(Signed) Kenneth A. Kenyon
Kenneth A. Kenyon,
Assistant Secretary.
the Board also
(The letter to the Reserve Bank stated that
allowed to
period
the
of
had approved a six-month extension
be
should
extension
establish the branch; and that if an
letter
the
Board's
in
requested, the procedure prescribed
of November 9, 1962 (S-1846), should be followed.)

2264
Item No. 2

BOARD OF GOVERNORS

7/11/63

OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON 25, D. C.
ADORESS OFFICIAL CORRESPONOENCE
TO THE BOARD

July 11, 1963

Board of Directors,
The Elyria Savings & Trust Company,
Elyria, Ohio.
Gentlemen:
The Board of Governors of the Federal
Reserve System extends to June 25,1964, the time
within which The Elyria Savings & Trust Company,
Elyria, Ohio, may establish a branch on the south
side of Cleveland-Elyria Road east of the intersection of Avon-Belden Road, North Ridgeville,
Ohio, provided that branch operations conducted
at 7077 Avon-Belden Road, North Ridgeville, are
discontinued simultaneously with the establishment
of the above branch.
Very truly yours,
(Signed) Kenneth A. Kenyon

Kenneth A. Kenyon,
Assistant Secretary.

2265
BOARD OF GOVERNORS

Item No. 3
7/11/63

OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON 25, D. C.

•

ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD
•
,
•kif. RESt

July 11, 1963

Board of Directors,
Union Trust Company of Maryland,
Baltimore, Maryland.
Gentlemen:
The Board of Governors of the Federal
Reserve System approves the establishment by
Union Trust Company of Maryland, Baltimore, Maryland,
of a branch at Belcamp, Maryland, provided the branch
is established within six months from the date of
this letter.
Very truly yours,
(Signed) Kenneth A. Kenyon
Kenneth A. Kenyon,
Assistant Secretary.
(The letter to the Reserve Bank stated that the
Board also had approved a six-month extension
of the period allowed to establish the branch;
and that if an extension should be requested,
the procedure prescribed in the Board's letter
of November 9, 1962 (S--1846), should be followed.)

,266
2
Item No. 4

BOARD OF GOVERNORS

7/11/63

OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON 25, D. C.
ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

July 11, 1963
Bankers Dispatch Corporation,

, 4658 South Kedzie Avenue,
Chicago 32, Illinois.
Gentlemen:
This refers to the request contained in a letter dated
May 24, 1963, submitted to the Federal Reserve Bank of Chicago by Andrew
G. Pitt, Esquire, for a determination by the Board of Governors of the
Federal Reserve System as to the status of Bankers Dispatch Corporation
as a holding company affiliate.
From the information presented, the Board understands that
Bankers Dispatch Corporation is engaged, through five wholly-owned
subsidiaries, in the transportation of commercial papers, documents and
non-negotiable instruments for banks, the transportation of exposed color
film and prints, microfilm and general office records, the delivery of
mail to and from post offices in Chicago for their customers, the conduct
of a check cashing business in the Chicago area, and, through a sixth
wholly-owned subsidiary, the purchase of vehicles used by the other
subsidiaries to which they are leased on a monthly rental basis; that
the Corporation is a holding company affiliate by reason of the fact
that it owns, directly and indirectly, 14,600 of the 26,208 shares of
common stock of The District National Bank of Chicago voted for the
election of directors at the stockholders' meeting on January 8, 1963;
that the Corporation also owns, indirectly, 2,100 of the 15,000 outstanding shares of capital stock of The Archer National Bank of Chicar,o; and
that the Corporation does not, directly or indirectly, own or control any
stock of, or manage or control, any other banking institution.
In view of these facts, the Board has determined that Rankers
is not engaged, directly or indirectly, as a busiCorporation
Dispatch
ness in holding the stock of, or managing or controlling, banks, banking
associations, savings banks, or trust companies within the meaning of
section 2(c) of the Banking Act of 1933 (12 U.S.C. 221a); and, accordingly,
the Corporation is not deemed to be a holding company affiliate except
for the purposes of section 23A of the Federal Reserve Act, and does not
need a voting permit from the Board of Governors in order to vote the
bank stock which it owns.

BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM

Bankers Dispatch Corporation

-2-

If, however, the facts should at any time indicate that Bankers
patch Corporation might be deemed to be so engaged, this matter should
!Fain be submitted to the Board. The Board reserves the right to rescind
ris determination and make further determination of this matter at any
ms on the basis of the then existing facts. Should future activities
;1) or acquisitions by Bankers Dispatch Corporation or its subsidiaries,
itrticularly in bank stocks, even though not constituting control, result
its attaining a position whereby the Board may deem desirable a determilation that the Corporation is engaged as a business in the holding of
114nk stock, or the managing or controlling of banks, the determination
erein granted may be rescinded.

I

Very truly yours,

Kenneth A. Kenyon,
Assistant Secretary.

BOARD OF GOVERNORS

Item No.

5

7/11/63

OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON 25. D. C.
ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

July 111 1963

,AIR MAIL
Mr. Leland Ross, Vice President,
Federal Reserve Bank of Chicago,
P. 0. Box 834)
Chicago 901 Illinois.
Dear Mr. Ross:
This refers to your letter of May 31, 1963, relating to the
status of Bankers Dispatch Corporation, Chicago, Illinois, as a
holding company affiliate of the District National Bank of Chicago,
Chicago, Illinois.
There is enclosed for transmittal a letter of this date
addressed to Bankers Dispatch Corporation advising it of the action
taken by the Board with reference to this matter. A copy of the
letter is also enclosed for your files.
In view of the fact that the application submitted by Bankers
TA-ePatch Corporation represents that there may very well be further
acquisitions of bank stocks in the future, it would be very much
aPPreciated if you would keep the situation under review and furnish
the Board with a summary of the status of this case each year, including:
(1) information as to bank stocks controlled together with a percentage
°f the total assets of the Corporation represented by the investment
n bank stocks, obtained either from examination reports of banks or
'rcm the Corporation directly; and (2) information obtained from
!
)
camination reports of banks in which the Corporation has an interest as
the degree and results of control of policies, if any, by the
uorporation in banks in which it has an interest.

I

Very truly yours,

AT7
7.
Kenneth A. Kenyon,
Assistant Secretary.
Enclosures

2269
S-1879
Item No. 6

BOARD OF GOVERNORS

7/11/63

OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON 25. D. C.
ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

July 22, 1963.

Dear Sir:
This letter supplements the Board's letter S-1872,
dated May 29, 1963, with respect to applications by State member
banks for permission, under applicable provisions of Standard
y
Condition of Membership Number 1, to exercise statutory fiduciar
powers.
In appropriate cases, in the discretion of the Reserve
Bank, such applications should be the subject of a field investigation, including an interview with the bank's directors and
executive officers at which the responsibilities and potential
liabilities inherent in fiduciary activities are fully explored,
together with the requirements for sound and creditable administration of fiduciary appointments.
With respect to each such application (whether the
or
Reserve Bank is to advise of approval on behalf of the Board
action-for
Board
to
the
d
forwarde
be
to
whether the application is
see S-1872) the Reserve Bank will prepare a memorandum supporting
its conclusion relative to the appropriateness of the exercise of
the powers for which permission has been requested. Such memorandum
shall reflect the results of the field investigation, if any, and
shall include a recitation and analysis of all factors of importance
bearing on whether the requested permission should be granted, i.e.,
the condition of the member bank and the adequacy of its capital
structure; the general character and ability of the management of
the bank; local conditions, including the competitive situation,
to
affecting the need for the corporate fiduciary services desired
and
,
s,
officers
director
those
of
be furnished; qualifications
employees who would be responsible for supervision and administration of fiduciary activities; and the availability of legal counsel
to advise and pass upon fiduciary matters.

270
S-1879

-2-

d
enclosed which should be use
A form of letter-advice is
in
ned
tai
con
k, under authority
in each case where a Reserve Ban
sion to a
rd in granting permis
Boa
S-1872, acts on behalf of the
. As in
ers
pow
statutory fiduciary
State member bank to exercise
ter of
let
the
ations, a copy of
the case of Board-approved applic
ities.
hor
aut
interested State banking
authority may be furnished
Very truly yours,

Merritt
Secre
Enclosure

ERAL RESERVE BANKS.
TO THE PRESIDENTS OF ALL FED

Al
n,

S-1879-a

Suggested letter of advice to State member bank authorizing, on behalf
of the Board of Governors, the exercise of fiduciary powers.

Board of Directors,
(Name of Bank),
(City), (State).
Gentlemen:
Consideration has been given to your request for permission,
under applicable provisions of your condition of membership numbered 1,
to exercise fiduciary powers.
if:44,111LE..4.5es involving exercise of full statutory powers)
On behalf of the Board of Governors of the Federal Reserve
to exercise

System, permission is hereby granted to

any and all fiduciary powers now or hereafter conferred upon such bank
by or pursuant to the laws of the State of
SFor cases involving limited exercise of statutory powers)
On behalf of the Board of Governors of the Federal Reserve
System, permission is hereby granted to

to act as

With the understanding that (fiduciary appointments of other kinds)
(any other fiduciary appointments) will not be accepted without first
Obtaining the permission of the Board.
Very truly yours,

(To be signed by President or
First Vice President)

'•)

Item No. 7

BOARD OF GOVERNORS

7/11/63

OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON 25.. D. C.
ADDRESS orriciAL CORRESPONDENCE
TO THE BOARD

July 11, 1963.

Mr. A. J. Faulstich,
Administrative Assistant to the
Comptroller of the Currency,
Department of the Treasury,
Washington 25, D. C.
Dear Mr. Faulstich:
This refers to your letter of June 28 concerning
e
accumulated annual leave of employees of the Federal Reserv
the
that
ing
suggest
and
on,
Issue and Redemption Divisi
of
liability for such leave should be provided for as part
ty.
activi
the recognized cost of this
It is the Board's understanding that salary costs
for
of the Federal Reserve Issue and Redemption Division,
always
have
Board,
the
from
claimed
which reimbursement is
Annual
included any amounts that have been paid pursuant to
ees.
l
employ
Federa
to
ble
applica
ions
and Sick Leave Regulat
The Board prefers to continue this method of
Governreimbursement, as it conforms with the practice by
sum
ment agencies whereby the employing agency makes lump
leave the
payments for annual leave at the time employees
Federal service.
Very truly yours,

Kenneth A. Kenyon,
Assistant Secretary.