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t

59

Minutes of actions taken by the Board of Governors of the
Federal Reserve System on Tuesday, June 19, 1951. The Board met in
the Board Room at 10:35 a.m.
PRESENT:

Mr.
Mr.
Mr.
Mr.

Martin, Chairman
Szymczak
Vardaman
Powell
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.

Carpenter, Secretary
Sherman, Assistant Secretary
Kenyon, Assistant Secretary
Thurston, Assistant to the Board
Thomas, Economic Adviser to the Board
Leonard, Director, Division of Bank
Operations
Mr. Vest, General Counsel
Mr. Young, Director, Division of Research
and Statistics
Mr. Noyes, Director, Division of Selective
Credit Regulation
Mr. Youngdahl, Chief, Government Finance
Section, Division of Research and
Statistics
Mr. Leach, Economist, Division of Research
and Statistics
Mr. J. J. Smith, Special Counsel
Reference was made to a request filed under date of June 14,

1951 by
attorneys for Transamerica Corporation pursuant to Rule IX of

the

Board Is Rules of Procedure requesting that, because of the complex

riature of the proceeding in the matter of Transamerica Corporation, the
311°Pe of the record, and the numerous issues of fact and law
which will
be
Presented
by Respondent's exceptions and objections to the Recommended
beet
sion of
the Hearing Officer dated June 13, 1951, the matter be set
44111 tor oral
argument before the full Board. Reference was also made
to a

Motion by Counsel for Transamerica dated June
14, 1951, that the




-2time limit set in the Board's Order of May 15, 1951, for filing of
exceptions, objections, and briefs to the Recommended Decision of the
Rearing Officer be extended from July 13 to September 13, 1951, and
that the time limit for filing reply- briefs, as fixed in the same
Order,
be extended
from July 30 to October 12 1951.
Chairman Martin called upon Mr. Smith who said that he would
recommend that the request for oral
argument before the full Board be
granted. He pointed out that the Board was not requested to fix a date
for oral argument at this time but added that if the
request was granted,
he felt there should be
an interval of several weeks between the time
of announcement
of the date and the day on which oral argument would
take place.
With respect to the motion for additional time to file and brief
exceptions and objections to the Recommended Decision of the Hearing
C4rficer, Mr. Smith stated that he felt the minimum time that should be
411"ed by the Board would be 60 days from
June 132 the day on which
the Recommended
Decision was filed. While he did not believe there would
be
error
in a legal sense in denying the motion for an extension of 60
c1413% beyond
the 30 days already granted and allowing an extension of, say2
30 dA
4e, Mr. Smith expressed the opinion that because of the length and
%1PlexitY of the case, the nature of the recommendations in the
Hearing
'erts Recommended Decision, the fact that the
newer members of the
130ard
1 uld have to study and familiarize themselves with
"
the case, and




6/19/51

-3-

the fact that this was the vacation season, there was justification for
granting the motion as made.
Mr. Vest stated that he felt substantially as Mr. Smith had expressed himself with respect to the motion for additional time, that
there was justification for some extension of time beyond the 30 days
granted in the Board's Order of May 15, 1951, that from the legal standPoint an extension of 30 days would be entirely satisfactory, that he
had no strong feeling as to whether
the total time granted should be 60
or 90 days from the date the Recommended Decision was filed, but that he
clid not know of any important reason from the standpoint of public policy
or from the Board's
standpoint why the total of 90 days requested should
4(4 be permitted.
With respect to the request for oral argument) Mr. Vest said that
he felt strongly that the date for oral argument should be at least several
weeks sUbsequent to the time of announcement of the date, and that he also
felt that
a minimum of at least two weeks should be allowed between the
clate for filing reply briefs and the date for oral argument in order to
Pertlit the
attorneys for the Board and for the Respondent adequate time
to study them.
Chairman Martin said that he had discussed the matter by telephone
with Mr
4van5 who had stated that it would be his preference that a
Ooze_

nhat shorter
extension of time than that requested by Respondent be
klaoweA
`As Probably about 30 days extension in each instance beyond the




-fj

6/19/51

-4-

dates set by the Board's Order of May 15, 1951.

Chairman Martin went

on to say that, after careful consideration, he felt that because of

changes in the composition of the Board since the proceeding against
Transamerica was instituted, because of the possibility of misinterpretation of a denial or modification of the request of Transamerica, and
because of the relatively small difference in time requested and the
minimum recommended by Counsel for the Board, it would be desirable to
grant the motion as filed. He also suggested that since there appeared
to be no objection to the request for oral argument, that also be
granted.
Thereupon, upon motion duly
made and by unanimous vote, an
Order Was approved as follows:
"UNITED STATES OF AMERICA
BEFORE THE
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
IN THE MATTER OF
T
RANSAMERICA CORPORATION
ORDER GRANTING RESPONDENT'S REQUEST FOR ORAL
ARGUMENT AND MOTION FOR ADDITIONAL TIME TO
FILE AND BRIEF EXCEPTIONS AND OBJECTIONS
This matter coming on this day for consideration on resPondent Transamerica Corporation's Request for Oral Argument
Motion for Additional Time to File and Brief Exceptions and
)11Jecti0ns to the Recommended Decision of the Hearing Officer
uated June 13, 1951, and the Board having fully considered the
matter, it is ORDERED that:
1. The said Request and Motion be, and they hereby are,
granted.
2, This matter later be set down for oral argument before
"El Board on a date hereafter to be determined by the Board.
3. The time for filing exceptions, objections and briefs
cri
.ant to Rule VII of the Board's Rules of Practice for Formal
ilarings be, and it hereby is, extended to and including September
'
2 1951.




it

6/19/51

-5-

"4. The time for filing reply briefs pursuant to paragraph (b) of Rule VIII of the Board's Rules of Practice for
Formal Hearings be, and it hereby is, extended to and including
October 1, 1951.
This 19th day of June, 1951.
By the Board.
(signed) S. R. Carpenter,
Secretary.
Governor Eccles took no part in the Board's consideration
of or action upon the Request and Motion referred to in the
foregoing Order."
At this point Messrs. Townsend, Solicitor, and Chase, Assistant
Solicitor, joined the meeting, and Mr. Smith withdrew.
Mr. Thomas presented a report on developments in the Government
se

curities market, following which Messrs. Youngdahl and Leach withdrew.
Before the meeting there had been distributed to the members of

the Board copies of a memorandum from Chairman Martin, dated June 11,
1951, proposing that there be held at the Board's offices between October
1951
--nu June 1952, a series of six two-day meetings of Federal Reserve
Barile

and Branch directors similar to the pilot meeting of the directors

°f the Federal Reserve Banks of New York and Minneapolis and their
brannl.
'"63 which was held in conjunction with the Chairman's Conference on
rY 16 and 17, 1950. The memorandum stated that this series of
14"-Ilg3 would be part
of a program to promote closer relationships
between the
directors and the Board of Governors and would provide an
°P13°1‘tlirlitY for the members of the Board to obtain first-hand information
the

directors as well as for the directors to gain a better under4tarlm
"'rig of
thecperations and policies of the Board and of their own role




6/19/51

—6—

in the System as a whole.
In a discussion of the feasibility of such a series of meetings,
during which Messrs. Eccles, Norton, and Solomon, Assistant General
Counsel, joined the meeting, members of the Board present expressed
agreement as to the value of such meetings to the members of the Board,
to the directors, and to the Federal
Reserve System generally, but
questioned whether in view of the number of regular meetings such as
those of the Federal Open Market Committee, the Federal Advisory Council,
and the Presidents' Conference, it would be feasible to have six additional meetings of the type proposed within the suggested period of about

eight months. The thought also was expressed that it was important for
the members of the Board to undertake to visit the Reserve Banks regularlY, particularly on the occasion of directors' meetings of the re8Pective banks, and that meeting schedules should be arranged to permit
such visits.
At the conclusion of the discussion, Chairman Martin suggested
that no action with respect to the suggestion in his memorandum be taken
4.t 'this time and that further consideration be given the matter at a
later date.
This suggestion was approved unanimously
together with a suggestion by Mr. Vardaman
that to provide a basis for further discussion
Mr. Thurston be requested to review the schedule
of meetings in which the Board would participate
over the forthcoming twelve months and report to
the Board whether it appeared that a series of




tsti-;

6/19/51

-7meetings such as suggested in Chairman
Martin's memorandum could be arranged
which would harmonize with this schedule.
Chairman Martin then stated that Mr. Wilbur, Chairman of the

Chairmen's Conference, had raised the question of holding a meeting of
the Conference in San Francisco in late
October or early November of
this year, and had asked for an expression of the Board's views with reaPect to the advisability of having the meeting in that city since, if
it did not seem desirable, he would like to make plans for a Conference
iI Washington at approximately the time indicated.

Chairman Martin said

that he understood the Chairmen's Conference had met outside Washington
fl'om time to time including a meeting at the Federal Reserve Bank of New
tork last
September, that he felt there was much to be said for having
8144 meetings at the Federal Reserve Banks, but that in view of the
curinternational situation he questioned whether it would be desirable
t° schedule a meeting
of the Conference for next fall in San Francisco.
There followed a discussion during which it was suggested that
141i* Wilbur be advised that, in view of existing conditions,
the Board felt

that if
there was to be a meeting of the Chairmen's Conference next fall
It 811c)uld be held in Washington, and that it would seem desirable to defer
c4iling a meeting until about September 1, 19510 with the thought
that
%nsideration might then be given to setting a time for a meeting either
later
this year
or in the spring of 1952.




This suggestion was approved
unanimously.

4

6/19/51

-8In this connection, Mr. Vardaman referred to a letter which he

had written to the Chairman of the Chairmen's Conference under date of
June 14, 1949, following their meeting at White Sulphur Springs, West
Virginia, in May of that year, stating why he had not attended that Conference and expressing the hope that future meetings of the Chairmen
ftuld be held either in Washington or at one of the twelve Federal Reserve
Banks.

He added that he still felt as he had indicated in that letter.
Mr. Carpenter reported that in accordance with the understanding

at the meeting of the Board on June 12, 1951, he had advised Mr. Peyton,
Chairman of the Presidents' Conference, that the Board would have no
Objection if it should be the decision of the Presidents' Conference to
held its
September meeting in St. Louis at the time of the annual meeting
of the National Association of Supervisors of State Banks with the understanding that the Conference would be followed by a meeting of the Federal
°Pen Market Committee and a joint meeting of the Presidents and the Board
/r1 4ashington immediately after the annual convention of the American
13ankers Association. He reported that President Peyton had now advised
bY letter dated June 15, 1951, that such a schedule would be followed.
Mr. Townsend referred to the matter of Public Loan Corporation,
it8 manager, Walter L. Boynton, and Herman Bryan Hamric, doing business
as
41-0 Motor Sales, all of San Francisco, California, involving ap'
atellt collusion to violate the terms of Regulation 01, Consumer Credit,




—9—

6/19/51

which had been referred to the Department of Justice for possible criminal
action in accordance with the action taken at the meeting of the Board on
UV 8, 1951, and stated that while in San Francisco recently he had discussed the case with the United States Attorney's office in that city,
since at that time it had been referred to that office for prosecution.
Thereafter, Mr. Townsend said, the matter was recalled by the Department
of Justice for further consideration and it was his understanding that
no decision had yet been made by the Department as to the action to be
taken.
Mr. Townsend then presented the matters of Walter L. Lange,
doing business as Lange Television Sales, St. Paul, Minnesota; Sam Kay,
d°ing business as Arkansas Home Building and Repairing Co., Little Rock,
Ar
kansas; Andrew C. Cain, William C. Cain, and Lee Bing, doing business
ae'
114
-j
14-"
4
-Le Sewing Dealers, New Orleans, Louisiana; and Personal Finance
Co
PanY, Yonkers, New York (a subsidiary of Beneficial Loan Corporation,
which controls small loan companies operating in 36 States); each of which
eases had been referred to the Board by the Reserve Banks of the respective
cilicts as involving apparent violations of Regulation K, Consumer
el'edit, and stated that in accordance with the recommendation of the Reset'" Bank in each instance it was his recommendation that the matters
be referred to the
Department of Justice for consideration whether crimi441 Pr
oceedings should be instituted.




6/19/51

-10During the presentation of the foregoing matters, Mr. Heath,

Acting Assistant Director, Division of Selective Credit Regulation,
joined the meeting.
Mr. Vardaman objected to the procedure now being followed in
connection with cases arising under Regulation WI Consumer Credit, and
Regulation X, Real Estate Credit, involving references to the Department
Of Justice for the possible institution of criminal proceedings, and
suggested that consideration be given to a procedure whereby the Board
would delegate to the Federal Reserve Bank located in the district
Where the apparent violation occurred the responsibility for referring
direct to the local United States Attorney any case which it felt should
be transmitted for possible criminal proceedings.
In the discussion of Mr. Vardaman's suggestion, the opinion was
exPressed by Mr. Eccles, and it was the consensus of the members present,
that it would be desirable to have as much as possible of the enforcement
w°rk in connection with Regulations iff

and X handled by the Federal

Reserve Banks to as to avoid the need for adding to the staff of the
Solicitor's Office.
During this discussion, Chairman Martin withdrew from the meeting
to keep an appointment.




During the discussion, it WAS agreed
unanimously that in the absence of Mr. Evans
the matter be referred to Mr. Norton as the

6/19/51

-11member of the Board having the assignment
of matters relating to Regulations W and X,
with the understanding that he would review
with Messrs. Townsend, Vest, and Carpenter,
in the light of the discussion at this meeting, the procedure now followed in referring
cases to the Department of Justice and the
holding of administrative hearings and present
to the Board recommendations as to how such
matters should be handled in the future. In
taking this action, it was understood that
pending adoption by the Board of a different
procedure, the present procedure for consideration of cases for possible reference to the
Department of Justice or for the institution
of administrative hearings would continue to
be followed.
At the conclusion of the discussion, upon
motion by Mr. Norton, it was voted unanimously
that reports of the four matters referred to
above be transmitted to the Department of
Justice in order that that Department might,
in its discretion, institute criminal proceedings.
Secretary's Note: Pursuant to the foregoing
action, a letter was sent to the Honorable James
M. McInerney, Assistant Attorney General, Department of Justice, Washington, D. C., under date of
June 251 1951, reading as follows, together with
similar letters, also dated June 250 19511 relating
to the matters involving Sam Kay, doing business
as Arkansas Home Building and Repairing Co., Little
Rock, Arkansas; Andrew C. Cain, William C. Cain,
and Lee Bing, doing business as Dixie Sewing
Dealers, New Orleans, Louisiana; and Personal Finance Company, Yonkers, New York:

"Pursuant to Section 21 of the Securities Exchange Act
of 1934, made applicable to the Board of Governors by Section
604 of the Defense Production Act of 19501 the Board of
Governors is transmitting to you herewith a report concerning
acts and practices which appear to the Board to constitute
vlolations of its Regulation W by Walter L. Lange, doing
business as Lange Television Sales, St. Paul, Minnesota.
This report is sent to you in order that you may, in your
discretion, institute criminal proceedings."




6/19/51

-12Mr. Townsend referred to the action of the Board on May 8, 1951,

authorizing the Solicitor to institute action to compel Maxim Appliance
Company, Bartow, Florida, a registrant under Regulation

Wy

to produce its

records and open its books for investigation, and stated that inasmuch as
the registrant had made his records available, it was recommended that
the Solicitor be authorized to take the necessary steps to obtain dismisSal of the suit that had been filed.
Upon motion by Mr. Norton,
this recommendation was approved
unanimously.
Mr. Heath withdrew from the meeting at this point.
Mr. Norton presented two memoranda dated June 19, 1951, stating
that in letters dated June 15, 1951, the Housing and Home Finance Administrator advised that, for reasons stated, he had concluded that the Vallejo,
California, and Quad Cities, Iowa-Illinois areas should be designated as
defense areas for the purpose of instituting special action to assist in
the production of necessary defense housing, and that he recommended that
if designation of the areas was concurred in by the Board, the schedules
of relaxed credit terms under Regulation X, Real Estate Credit, be similar
to those previously announced for other designated defense areas. Mr.
Norton stated that he recommended that the Board concur in the designations.




Thereupon, upon motion by Mr.
Norton, unanimous approval was given
to letters to Mr. Foley, Housing and
Home Finance Administrator, as follows:

A

i.t •i

6/19/51

e .1.

-13Letter regarding Vallejo, California area

"In response to your letter of June 150 1951, this
is to advise you that the Board of Governors concurs in
your designation of the Vallejo, California, area, including the communities of Benicia, Fairfield, Suisun,
and Vacaville, as an area for the application of special
credit terms under section 6(p) of Regulation X, Real
Estate Credit, for purposes of defense construction.
Your letter states that there is a need for approximately
600 housing units to be located within reasonable commuting distance of the Vallejo area, 480 to be rental
units ranging from $60 to $80 per month each, and 120 to
be sale units at $8,500 and $9,500 each. Under the
terms of the exemption, the entire 600 units will be controlled by your agency through the issuance of specific
certificates.
"In accordance with your suggestion, the relaxation
of terms prescribed by Regulation X will be similar to
that previously announced for other designated defense
areas."
Letter regardin

Quad Cities, Iowa-Illinois area

"In response to your letter of June 15, 1951, this
is to advise you that the Board of Governors concurs in your
designation of the Quad Cities, Iowa-Illinois, area, including Davenport, Iowa, Moline, Illinois, East Moline, Illinois,
and Rock Island, Illinois, as an area for the application of
sPecial credit terms under section 6(p) of Regulation X, Real
Estate Credit, for purposes of defense construction. Your
letter states that there is a need for approximately 750
housing units to be located within reasonable commuting distance of the Quad Cities area, 450 to be rental units ranging
from $60 to $75 per month each, and 300 to be sale units at
$10,000 and $11,000 each. Under the terms of the exemption,
he entire 750 units will be controlled by your agency through
he issuance
of specific certificates.
"In accordance with your suggestion, the relaxation of
term
--"8 prescribed by Regulation X will be similar to that previously announced for other designated defense areas."

t

Mr. Carpenter reported that in response to the request in a memoOm the President dated June 11, 1951, for the Board's suggestions




'

6/19/51

-14-

on material for inclusion in the President's Midyear Economic Report,
the staff had prepared a draft of statement incorporating such suggestions
together with a background statement of the general economic situation.
After discussion, it was suggested that copies of the two statements be furnished each member of the Board for review, with the understanding that if any member of the Board had changes to suggest in them
he would notify the Secretary and they would be discussed at a meeting
of the Board tomorrow afternoon or Thursday morning.
This suggestion was approved
unanimously.
All of the members of the staff then withdrew and the Board went
into executive session.
Following the executive session, Mr. Eccles, as Chairman pro tern,
reported to the Secretary that he had informed the members of the Board
Present that he proposed to submit his resignation as a member of the
Board on
Thursday, June 21, to be effective July 15, 1951, and that

the Board
had approved his recommendation that his secretary, Miss Egbert,
be continued on the pay roll for such period as might be necessary, but

in no event
beyond November 30, 1951, to afford her an opportunity to go
through Mr. Eccles' personal files for the purpose of determining what
illaterial should be turned over to the Board for its official files. Mr.
. celes also reported that at the end of that period Miss Egbert planned
resign.
tO




6/19/51

-15The action stated with respect to each of the matters herein-

after referred to was taken by the Board:
Minutes of action taken by the Board of Governors of the Federal
Reserve System on June 181 19511 were approved unanimously.
Memoranda dated June 141 19511 from Mr. Young, Director of
the Division of Research and Statistics, recommending increases in
the basic annual salaries of the following employees in that Division,
effective June 241 1951:
Name
TOT; M. Culbertson
Charles Trescott
Lois I. Steidel
Marjorie C. Capps
Bruna L. Natts
Jesse D. smith

Title
Economist
Library Assistant
Clerk
Clerk-Stenographer
Draftsman
Clerk-Messenger

Salary Increase
To
From
$4,777
$4,600

3,195
2,890
2,450
2,450
2,930

3,275
2,970
2,530
2,530
3,050

Approved unanimously.
Memorandum dated June 12, 1951, from Mr. Bethea, Director of

the Division of Administrative Services, recommending increases in the
basic annual salaries of the following employees in that Division,
effective June 241 1951:
Name
Stanley J.
Bloch
John N. Lyon
Franklin Taylor
P
rank W. Constable
Bruce L.
Moffett
Nelson S. Dyson

Title
Assistant Supervisor,
Duplicating and Mail Section
Accountant
Clerk (Composition)
Photographer (Offset)
Offset Press Operator
Bindery Worker

Salary Increase
From
To
4,450
4,315

3,950
3,825
3,825
3,450
3,450

4,075
3,950
311950
3,575
3,575

Approved unanimously.

Memorandum dated June 151 19511 from Mr. Horbett, Assistant
l'ector of the Division of Bank Operations, recommending that the




6/19/51

-16-

resignation of Mrs. Betty Jane Vogenitz, Clerk-Typist in that Division,
be accepted to be effective, in accordance with her request, at the
Close of business June 29, 1951.
Approved unanimously.
Memorandum dated June 18, 1951, from Mr. Bethea, Director of
the Division of Administrative Services, recommending that the resignation of Miss Constance F. McCarthy, Clerk in that Division, be accepted to be effective, in accordance with her request, at the close
of business June
18, 1951.
Approved unanimously.
Memorandum dated June 15, 1951, from Mr. Noyes, Director of
the Division of Selective Credit Regulation, recommending that the
resignation of Miss Betty Jean Plaugher, Stenographer in that Division,
which had been approved effective June 22, 1951, be rescinded.
Approved unanimously.
Letter to Mr. Morrison, Vice President of the Federal Reserve
Bank

of Cleveland, reading as follows:
"In view of the circumstances described in your
letter of June 15, 1951, the Board of Governors approves
the payment of salary to Miss Helen Hater, Check Colz.
Stenographer, Cincinnati Branch, for an additional period of one month from July 1, 1951, at the
rate of $2,580 per annum, which is $120 below the minimuM established for the grade in which her position is
cl
assified."




Approved unanimously.

6/19/51

-17Letter to Mr. Diercks, Vice President of the Federal Reserve

Bank of Chicago, reading as follows:
"In accordance with the request contained in your
letter of June 15, 1951, the Board approves the appointment of Carl F. Spaeth, Jr., at present an assistant
examiner, as an examiner for the Federal Reserve Bank of
Chicago. Please advise us of the date upon which the
appointment becomes effective."
Approved unanimously.
Letter to Mr. Latham, Vice President of the Federal Reserve
sank of Boston, reading as follows:
"In view of your request and the information contained in your letter of June 14, 1951, the Board of
Governors extends to December 18, 1951, the time within
which the Union Trust Company of Springfield, Springfield,
Massachusetts, may establish a branch in West Springfield,
Massachusetts, under the authority granted in the Board's
letter of December 18, 1950."
Approved unanimously.
Letter to Mr. Slade, Vice President of the Federal Reserve
Bank

of San Francisco, reading as follows:
"Reference is made to your letter of June 7, 1951,
regarding the request of the Seattle Trust and Savings
Bank, Seattle, Washington, for permission to establish a
branch between 175th and 185th Streets, on Aurora Avenue,
outside the corporate limits of the City of Seattle,
Washington.
"In view of your recommendation, the Board of Governors
aPproves the establishment and operation of a branch between
175th and 185th Streets, on Aurora Avenue, outside the corpo!ate limits of the City of Seattle by the Seattle Trust and
6avIngs Bank, Seattle, Washington, provided the prior approval
c)f the appropriate State authorities is obtained and the branch




6/19/51
"is established within six months of the date of this
letter. It is understood that this approval covers the
establishment of only one branch in the above defined
area. The Board approved the establishment and operation
of a branch between 180th and 185th Streets, by Seattle
Trust and Savings Bank on July 2, 1946. It is understood
that it is the intent of the parties that the authority
granted on July 2, 1946, should be and it is hereby cancelled.
"It is further understood that Counsel for the Reserve
Bank will review and satisfy himself as to the legality of
all steps taken to establish the branch."
Approved unanimously.
Letter to Mr. DeMoss, Vice President of the Federal Reserve
13azk

Of Dallas, reading as follows:
.
"Reference is made to your letter of June 8, 1951, submitting the request of the Southern Arizona Bank and Trust
Company, Tucson, Arizona, for permission to establish an
additional branch within the metropolitan area of Tucson,
but outside the city's corporate limits.
"In view of your recommendation, the Board of Governors
approves the establishment and operation of a branch on
Alvernon near Broadway, outside the corporate limits of
Tucson, Arizona, by the Southern Arizona Bank and Trust
C?mPallY, Tucson, Arizona, provided the branch is established
Within six months from the date of this letter.
"It is understood that Counsel for the Reserve Bank
Will review and satisfy himself as to the legality of all
s eps taken to establish the branch."
Approved unanimously.
Letter to the Honorable Overton Brooks, House of Representatives,

Wa b
Ington,

D. C., reading as follows:

"Your letter of May 22, 1951, addressed to the National
Production Authority, with which you enclosed a letter from
Leon J. Phillips, President, Motor Securities Company, Inc.,
eveport, Louisiana, has been referred to us for reply since




6/19/51

-19-

"this Board is charged with responsibility for Regulation
W concerning consumer credit. Mr. Phillips' letter relates
to the down payment and maturity requirements of Regulation
as they pertain to used automobiles.
"One of the major problems involved in administering
a regulation such as this is to make it restrictive enough
so that it will be effective in accomplishing its over-all
purposes but at the same time to keep the regulation from
being an excessive burden on the people who are subject to
it. The Board has felt that relatively tight terms for instalment credit are required at present in order to help
restrain the strong inflationary pressures that are tending
to raise the prices of all goods and services. We are certain
You understand the necessity for avoiding the widespread
hardships which would prevail if inflationary tendencies in
the economy as a whole were allowed to continue unabated.
"Mr. Phillips claims that the sale of used cars does
not involve the use of critical materials or labor. This
is, of course, true. The expansion of instalment credit
for the purchase of used cars if this credit were not regulated would, however, contribute to an inflationary increase
in demand for articles that do use critical materials. Any
increase in demand for used cars would tend to spread to the
demand for new cars either directly or via the trade-in.
Moreover, any expansion of credit buying encouraged by easier
terms would tend to circulate throughout the economy in the
form of larger demand for all consumer goods.
"He also stated that lit is very unfair to the laboring
class for them to be required to pay one-third down on a used
automobile and the balance in fifteen months when a man who
has the money to pay cash can buy all of the new cars he wants
Or a good used car'. Regulation W as you know is not a rationing instrument. As a credit control instrument it is
necessarily limited in its effect to the users of credit.
The main purpose of Regulation W is to reduce the extent to
ich over-all consumer purchasing power is expanded through
lupe use of instalment credit. It is only one part of a
.road anti-inflationary program designed to halt the decline
_111 the purchasing power of the dollar, which, if continued,
would hurt especially the lower-income groups.
"One of the points made in the Special Bulletin which
4r Phillips enclosed with his letter was that old cars are
:menace to
traffic safety. While statistics for one comnitY may not be typical of the entire country, nevertheless
erding to police statistics, two of every three cars inv Ived in
traffic accidents in Washington, D. C. are postwar

n




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-20-

"cars, although the total number of registrations of postwar
and prewar is approximately equal. Furthermore, in roughly
nine of every ten accidents the cause is due to some failure
of the driver rather than any mechanical failure of the car2
and where mechanical failure is the principal cause of an
accident this is, in the great majority of cases, the result
of improper maintenance, and not the age of the car.
"We appreciate this opportunity of commenting on Mr.
Phillips' letter, which is returned herewith as requested."
Approved unanimously.
Telegram to the Presidents of all Federal Reserve Banks, reading
as follows:
"A Federal Reserve Bank has raised the question whether
lenders engaged in the business of extending real estate
credit in the territories and possessions of the United States
are required to file registration statements under Regulation X.
"In view of section 6(c) of the regulation, very few extensions of credit by such lenders will be subject to the
regulation, and the Board will raise no objection if such
lenders do not file registration statements in accordance
nth the Board's public announcement of May 112 1951."




Approved unanimously.