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A meeting of the Board of Governors of the Federal Reserve
System was held in Washington on Wednesday, March 16, 1938, at 11:30
a. m e
PRESENT:

Mr. Ransom, Vice Chairman
Mr. Davis
Mr.
Mr.
Mr.
Mr.

Morrill, Secretary
Bethea, Assi stunt Secretary
Carpenter, Assistant Secretary
Clayton, Assistant to the Chairman

Consideration was given to each of the matters hereinafter referred to and the action stated with respect thereto was taken by the
Board:
Letter to Mr. Young, President of the Federal Reserve Bank of
Boston, reading as follows:
"Receipt is acknowledged of your letter of February
10, 1938, relating to the payment of compensation to Associate Counsel Phillips Ketchum in addition to his annual retainer, in response to which you are advised that the Board
approves the payment to him of $1,900 for professional services to December 31, 1937 and 459.27 for cash disbursements
during the same period.
"In this connection, it is noted that Mr. Ketchum's
bill is apparently based upon total services for the period
extending from April 1, 1934 to December 31, 1937, less the
retainer paid, whereas, the Board has understood that the
retainer covered general consultation requiring no special
study, and that additional compensation would be paid only
for special work or litigation.
"The Board realizes that there are circumstances in
which, in order to secure the services of competent counsel
in special matters or special litigation, payment of an annual retainer bearing some relation to the work normally
to be expected may be desirable. The Board also realizes
that it may be awkward and undesirable to establish any
hard and fast rule relating to a division of work between
your General Counsel and your Associate Counsel; that, as




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"stated by you, the time may came when the need for Associate Counsel will be less; and that there may be very little
likelihood of embarrassment because of any indefiniteness in
the present arrangement.
"However, since the present arrangement, as understood
by the Board, is apparently indefinite, it will be appreciated if you will give consideration to clarifying it with
Mr. Ketchum with respect to the contemplated scope of his
services."
Approved unanimously.
Letter to Honorable William G. McAdoo, United States Senate,
reading as follows:
"This refers to your letter of February 10, 1938, requesting certain information regarding so-called holding
companies for banks in the United States and the banks controlled by them.
"In order to indicate clearly the scope of the information presented herewith in reply, it seems desirable to define the terms used in discussing the matter. Data submitted
herewith relate to organizations which fall within the definition of the term 'holding company affiliate' as set forth
in section 2(c) of the Banking Act of 1933, as emended, which,
as you know, includes any corporation, business trust, association, or other similar organization which owns or controls,
directly or indirectly, either a majority of the shares of
capital stock of a member bank or more than 50 per cent of
the number of shares voted for the election of directors
of the bank at the preceding election, or controls in any
manner the election of a majority of the directors of the
bank, or for the benefit of whose shareholders or members
all or substantially all the capital stock of a member bank
is held by trustees. In compiling data submitted herewith
regarding the banks controlled by such holding company affiliates, banks have been regarded as 'controlled' if they
were related to a holding company affiliate in any manner
described in the statutory definition just referred to,
wi.th the exception that banks are included which, although
not technically controlled by holding company affiliates,
would be subsidiaries of such organizations if the Reconstruction Finance Corporation did not hold preferred stock
of the banks.




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"It may be noted in this connection that the information
submitted to you with the Board's letter of December 18,
1937, in response to your letter of December 8, 1937, was
compiled on the same basis as that outlined above. You will
recall that the information submitted to you at that time
Included a list of 41 holding company affiliates, together
with information as to the number and aggregate resources
of the national, State member, and nonmember banks controlled
by them.
"In compliance with your current request, there is inclosed an additional tabulation of the 41 holding company
affiliates and their controlled banks, which shows the State
in which each holding company affiliate was organized, the
number of banks controlled by each, and the total deposits
of such banks. As in the case of the data submitted with
the Board's letter of December 18, the inclosed tabulation
has been compiled on the basis of the latest information in
the Board's records in connection with the issuance of voting permits pursuant to the applicable provisions of the
Banking Act of 1933. Also, as in the previous case, the
holding company affiliates listed in the tabulation do not
include organizations which have been determined by the
Board, pursuant to section 2(c) of the Banking Act of 1933,
as amended, not to be engaged as e business in holding the
stock of, or managing or controlling banks, and which therefore are not subject to the statutory requirements regarding
voting permits. To date, the Board has made such determinations with respect to 96 organizations. Although the
facts with regard to these determinations varied, the Board's
basic consideration in making them has been whether the organizations were engaged in the business of group banking,
and in most of the cases the organization controlled only
one bank.
"In connection with the controlled banks shown in the
tabulation, it must be recognized that the facts regarding
control of banks change from time to time by reason of
various factors, such as changes in the outstanding capital
stock of banks or changes in the proportion of stock owned
or controlled by holding company affiliates. The Board does
not receive immediate advice as to the occurrence of changes
in the status of control, but the data submitted herewith
show the situation as indicated by the most recent information in the Board's possession.
"You requested also a statement of the annual increase
in the number of holding companies for the years 1930-1937,




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"inclusive. It is regretted that the Board's records do
not contain the information necessary to show the net annual' increase or decrease in the number of all holding company affiliates for the period indicated. However, the applications for voting permits filed with the Board by holding company affiliates and other information in the Board's
records show that 37 of the 41 organizations listed in the
Inclosed tabulation were organized prior to 1930, and the
other four were organized as follows:
Holdin

camoany affiliate

Barnett National Securities Corporation,
Jacksonville, Florida

Year organized
1930

Hamilton National Associates, Incorporated,
Chattanooga, Tennessee
Florida National Group, Inc.,
Jacksonville, Florida

1932

New Hampshire Bankshares, Inc.,
Nashua, New Hampshire

1934

1930

"For your further information in connection with the subject of group banking in general, there is inclosed a copy
of the Federal Reserve Bulletin for February, 1938, which contains at pages 92-101, inclusive, a statistical survey of
group banking in the United States. You will note that, on
the basis of statistics as of December 31, 1936, there were
52 groups, comprehending 479 banks with loans and investments
of $5,460,000,000 and deposits of $6,840,000,000.
"It should be noted particularly that in the Bulletin
article, the subject of group banking was approached for
statistical purposes on a basis differing in certain respects
from the basis of the more current data in the inclosed tabulation. Among the more important differences is the fact
that the concepts of group banking and control of banks used
in compiling the published statistical data go beyond the
statutory definition of the term 'holding company affiliate',
as indicated by the definition shown on page 92 of the
Bulletin, which included among group banks those which were
controlled by 'what is regarded generally as a bank group
even though there is technically no "holding company affiliate" as defined in section 2(c) of the Banking Act of 1933'.
Also, it will be noted from the footnote numbered 4 on page
92 that the banks included in the published survey were not
all controlled banks, but included certain large banks,




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"which had deposits aggregating approximately $2,100,000,000,
which dominated their respective groups rather than being
subsidiary banks.
"Moreover, changes in the status of control of some banks
have occurred since December 31, 1936. For example, at that
time Transamerica Corporation controlled almost all of the
stock of Bank of America National Trust and Savings Association, San Francisco, California, but on the basis of the
information in the Board's possession, the bank ceased, in
1937, to be technically a subsidiary of such corporation.
Accordingly, the bank is not included in the current figures
shown in the inclosed tabulation, although it was, of course,
included in the statistical survey as of December 31, 1936,
and even now might properly be included in group bank figures
which are not limited to the statutory definition of control."
Approved unanimously.
Letter to Mr. Parker, First Vice President of the Federal 'Reserve Bank of Atlanta, reading as follows:
"Reference is made to your telephone conversation of
March 9 with Mr. Paulger regarding the problem of obtaining a sufficient number of examiners and assistants to
conduct a simultaneous examination of the head office of
the Commerce Union Bank, Nashville, Tennessee, and its
branches in connection with a proposed consolidation of the
State member with its affiliated national bank.
"It is understood that you have made arrangements to
obtain the services of some of the national examiners and
assistants assigned to that district, of which arrangement
Mr. Paulger advised you that there would be no objection.
Therefore, the Board approves the use by your bank of any
national bank examiner or assistant national bank examiner
in the examination of a State member bank made pursuant to
the provisions of section 9 of the Federal Reserve Act, such
approval being in order to avoid any question as to the right
under the law of these examiners to participate in examinations of State member banks. It will not be necessary for
you to submit the names of the individuals to the Board in
accordance with the procedure outlined in the Board's letter
of April 3, 1937 (X-9858), and you will note that under
this approval the use of the services of national examiners
and assistants is not limited to the Commerce Union Bank."
Approved unanimously.
Letter dated March 15, 1938, to Honorable Hattie W. Caraway,




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United States Senate, reading as follows:
"This refers to your letter of March 12, 1938, requesting advice as to whether or not there is a Federal criminal
statute forbidding the making or circulating of false statements derogatory to the financial condition or affecting
the solvency or financial standing of a member bank of the
Federal Reserve System.
"You are advised that there is no Federal statute of
general applicability upon tais subject although section
300c of the Code of the District of Columbia, which section
was enacted on March 4, 1933, forbids, under penalty of
fine or imprisonment or both, the making or repeating of
any false statement imputing insolvency or unsound financial
condition to any bank, trust company, or building and loan
association in the District of Columbia.
"It is hoped that this gives you the desired information
regarding the existing Federal statutes on this subject."
Approved unanimously.
Letter to the Comptroller of the Currency, reading as follows:
"It is respectfully requested that you place a special
order with the Bureau of Engraving and Printing, supplementing the order requested June 19, 1937, for the printing of
Federal reserve notes of the 1934 Series in the amounts and
denominations stated for the Federal Reserve Bank of Chicago:
Amount
DenomiNumber of
sheets
nation
9,000
410,300,000
100
1,600
9,600,000"
500
Approved unanimously.
Memorandum to the heads of all divisions of the Board's staff,
reading as follows.

The memorandum had been approved by the Personnel

OcYmmittee:
"There is transmitted herewith a supply of Form F.R. 370,
one of which should be filled out for each employee in your
division who occupies a position junior to that of assistant
head of the division. The information called for by these
forms is to be used as a basis for compiling comparative
data desired by the Personnel Committee with regard to positions involving similar work or responsibilities within and
without the Board's organization.




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"Each employee should be requested to prepare a concise statement enumerating the duties which he performs.
He should describe first the class of work which consumes
the major portion of his time and indicate his other duties
in the order of their importance. The employee also should
indicate clearly whether the work is done without close
supervision or under the immediate direction of some other
person. In the event the employee's duties are entirely
or in part of a supervisory character, the kind of supervision exercised and the number of other employees coming
under his supervision should be stated. The statement should
then be reviewed by the employee's immediate supervisor and
any exceptions or omissions noted should be called to the
employee's attention. Uniform phraseology should be used
wherever possible in the description of the same or similar
duties. By way of illustration, typical descriptions of
the work of stenographers and of typists are attached.
"When both the employee and his supervisor are in agreement as to the accuracy and completeness of the written
statement, it should be typed on Form F.R. 370. In this
connection, it is suggested that you designate one person
In your division to receive all such statements, type them
on Form F.R. 370, obtain the initials of the supervisor
thereon, and follow up to see that the forms are otherwise
complete. The forms should then be handed to the division
head for his approval of the description of the work by
initials, subject, of course, to any qualifying remarks he
may desire to make regarding any cases in which he feels
the description overstates or understates the duties and
responsibilities of the employee.
"Please have all completed forms covering employees in
your division assembled end forwarded at one time to Mr.
Bethea, in his capacity as Budget Officer of the Board, not
later than ten days from the date of this memorandum."
Approved unanimously.
Thereupon the meeting adjourned.

Approved:




Vice Chairman.