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1593 A meeting of the Federal Reserve Board was held in 7iashington on Thursday, May 31, 1934, at 3:00 p. m. PRESENTS hr. Mr. Mr. Mr. Sr. Nr. Er. Black, Governor Hamlin Miller James Thomas Szymczak O'Connor Morrill, Secretary Bethea, Assistant Secretary Carpenter, Assistant Secretary Martin, Assistant to the Governor Wyatt, General Counsel Wingfield, Assistant Counsel Paulr,er, Chief of Division of Examinations Mr. Leonard, Federal Reserve Examiner Mr. Mr. Er. Mr. Mr. Er. Er. Governor Black stated that this morning Mr. Thomas had cone & 1t ° hiG office and expressed concern over the action taken by the )3c411'' 04 May 29, 1934 with regard to the City Bank Farmers Trust Com. Pazy, New York, Mew York, and that after discussing the matter with kr. '',t%u he (Governor Black) had called Mr. Case, Federal Reser ve 4ge/it at New York, on the telephone and requested that, if Mr. Case hEtd , ()'- advised the trust company in accordance with the Board's teleof l`e-Y 29, he withhold doing so pending receipt of further advice. GO-ire 111°1 'Black then reviewed, for the information of Liz'. O'Connor, the c ider ation which has been civen by the Board recently to the request Of the CitY 13a.nk Farmers Trust Company for the waiver or modification Of standard conditions of membership numbered 12, 17, and 18, in the event the trust company should make application for membership in the Naeral Reserve System. 1594 5/31/34 Z'. Thomas stated that he felt that in voting at the meeting °I1 Lay 29 the members had all voted for different reasons; that the result „ of the Board's action was the position that a trust company which does substantially ED commercial banking business is not eligi- ble' for tlembership in the Federal Reserve System, and that he was not in accord with that position, as the Federal Reserve Act expressly includes trust comp it the Act. *es in the definition of the term "bank" as used Lr. James stated that he had voted in favor of 11r. Hamlin's 111°ti011 for the reason that he was of the opinion that the affiliation c'f the trust company with the National City Bank was contrary to the ePirit and purpose of the Federal Reserve Act. 1:-re 6zymozak stated that he had voted in favor of Mr. Hamlin's rilotion for the reasons, (1) that no application had been received frcaz the trust company, and (2) that he was opposed to a waiver or t*dification of the three conditions of membership involved. Board Governor Black then suggested that if the action taken by the (3/1 LlaY 29 should be reconsidered the questions before the Board Would 1, -es (1) whether it will adhere to the policy established by the 13c3c`rd in 1925, in connection with the consideration of the elbility tc41111e111bership Of the southern Trust Company of kAarksville, Tennessee, and followed since that, time, that it will not admit to membership a trtzt company which does substantially no comnercial banking business, or whether it mill depart from that policy, and (2) whether the Board Villiag to waive the three conditions of membership referred to. 1595 5/31134 -3CAies -cion was raised as to reasons for the adoption by the Board of the existinr Policy, and it was stated that the Board had felt that a trust company doing no commercial banking business would h"e ne appreciable amount of deposits which mould require the maintenrlee of reserves at the Federal reserve bank; that it would not Pr°duee paper which would be e1iP7ib1e for rediscount with the Federal reserve 1,-0_ and that the trust company might get into a position Where it 'would need help which the Federal reserve bank would not be 4ble to „ tend. Szymczak moved thaL, in order that the Board may Tive further consideration to the two questions referred to by Governor Hack, the Board reconsider its action taken at the meeting °11 May 29, 1934, with regard to the request of the City Bank Farmers Trust Company for the waiver or modification of conditions of membership numbered 12, 17, and 18. Carried, unanimously. It was then moved that, in view of the fact that the Board has before it the question of a pos!ale application by a trust company for membership ?fl. the Federal Reserve System consideration of which Involves former action of the Board in declining nennership to a trust company which did substantially 110 cemclerci al banking business, the policy established by such action be reconsidered. Carried, unanimously, with the expressed understanding that, in voting for reconsideration of the policy, no member of the Board was committing himself as to the position he would take in voting on the policy itself. ,. Mr. James moved that the Beard adhere to the Polley followed by it since 1925 that a trust com)ukriY doin substantially no commercial banking busand receiving substantially no commercial 5131/34 4,deposits will not be admitted to membership in the Federal Reserve System. Motion lost, Messrs. Hamlin and James voting "aye". The members of the Board made the following statements as to their individual reasons for their vote on the above motion: Governor Black said that he voted "no" for the reasons that (1) in his opinion every substantial trust company should be a momor of the Federal Reserve System; (2) the Federal Reserve Act defines the word 't-oank 11 as including trust company, and provides that e bank may ' be admitted to the Federal Reserve System, which he conceived to mean that a trust company may be admitted, (3) he would not have acreed to the past policy of the Board had he been a member of the 130ard when it was adopted, although he would not criticize it, (4) he believed the Federal Reserve System should include not only ec/nmarcial bankT; and trust companies but mutual savings banks, Morris 11411 hanks and personal loan banks, as now permitted by the Act, and that a unified banking system should include all the different kinds of banks in the United states, and, (5) in his opinion, the admission Of truwt companies such as that under consideration will go a long 1.4'4Y t°ward building up and strengthening the Federal Reserve System, and there 15 no reason why such trust companies should not be admitted to /ribership. hi Mr. Idiller stated that he voted 11 " for the reason that in °Pitlion the last few years, particularly, had disclosed that one °e the zest needed improvements in the banking situation in this 1597 5/31/34 -5. country is a plan for the more effective discharge of the functions f truat companies; and that the Federal Reserve System and particularlY the p ederal Reserve Board in recent years have been devoting more t1° to the proper supervision of the activities of banks, both national and State member banks, that engage in trust business. he said the °IllY reason why he would hesitate to admit to membership an instituticll that is priml-rily a trust company would be a doubt that he still had, although it is diminishing, as to the competency of the Federal Reser. "System and the Board to adequately discharge the functions of atIPervision. He was willing, however, he said, to take a chance on that and felt that the admission to mmbershio of trust companies do11° commercial banking business would be the first definite indi".°11 Of an attitude on the part of the Board that it is milling to "11111e the re sponsibility of effective supervision of their activities, atid that En" supervision would be beneficial in all respects provided thc Work is Tiell done. He also added that his vote did not constitute s.blariket commitmont to admit any and all trust companies, but that \tier° there is nothin- that indicates that membership would not be de4 -411 Etre its the public interest for a trust company and for those who Patrons he would vote to admit the institution and thus bring it 114der Federal supervision. 4rs. liamlin stated that he voted "aye" (1) heallse the ille4333 havinfc lttlla be no the follinr followins reasons: admission of a trust company doing solely a trust bussubstantial amount of deposits or of commercial per, inconsistent with the purposes of the Federal Reserve Act, 1598 5/31/34 -6- (2)that such trust companies would not carry any substantial amount of reserves with the Federal reserve bank, and therefore would contribute nothing to the strength of the System, (3) that the admission of 31101 trust companies to membership would probably, in the opinion of the public at least, place upon the Federal Reserve System a moral °bligation, in case of trouble growing out of the administration of trusts, which latter constitutes substantially the only business by virtue of which these companies would have been admitted to membership, to grant relief to trust beneficiaries through advances to the trust "114)e-ties, which relief the Federal Reserve System could not grant in 611Y substantial amount under existing in ws Li-. James said the Federal Reserve System was established pri44111Y to furnish an elastic currency, to afford means of rediscounting 00312aercial Paper, to establish a more effective system of banking in the United States, and for other purposes". The fundamental basis of the Pederal Reserve System's activities is the reserves of its member 44'4' eince more than 90 per cent of the funds available for use by the Federal reserve banks consist of member bank deposits for reserve aocoUnt. The Paid-in capital of the Federal reserve banks amounts to lces than 4 per cent of these deposits. An institution having no dePosits would carry no reserve and would make no contribution, beyond it8 subscription to the capital stock of the Federal reserve bank, to the ftulds from which the Federal reserve bank could provide currency 411141 credit as needed. Accordingly, in his judgment, the admission of 44ch an institution to membership is not in accordance with the 1599 5/31/34 -7- PlIrPosec of the Federal Reserve Act and especially for that reason he Made the motion and voted in favor of the motion. Mr. Thomas stated that he was very much disturbed by the action taken by the Board on May 29, 1934; that he agreed with the above et4telnents made by Governor Black and Er. Miller and felt that in the rieversai of the Board's policy there is a distinct opportunity for the 4deral Reserve System to do a great public service as there have been a gl'eat many irregularities in trust companies in the past which might 33.clt have occurred had they been members of the Federal Reserve System alulhad accepted the conditions of membership prescribed by the Board; alld that for these reasons he had voted Itnoft on the resolution. Szymczak stated that he had voted "no" for the reasons 4ssrs. Black, Taller and Thomas and particularly for the tea8°11 that he felt the admission of trust companies to membership 'Would 1, "43 an aid to the achievement of a unified banking system. 14r• O'Connor referred to the fact that Section 1 of the FedReserve Act expressly includes trust companies in the definition °r the Vitird "baak" and he said that he did not find any limitation on the term trust company in the act and that, therefore, it seemed to hik that C ogress intended that trust companies should be permitted to e llicythe b enefits of membership. Be also said he believed that, by 8111)er.v.181011 by the Federal Reserve Board, a much better system for the stration of trusts can be established in the United States, that ror that reason the Federal Reserve Board should lend every encourageaellt to br irlg this very important part of the banking business under eral 1600 5/31/34 -8Control and that therefore he voted "no" on the above motio n. James moved that the Federal reserve banks be advised of the reversal by the Board of its Policy with regard to the admission to membe rship of trust companies doin substantia lly no coLimercial banking business, and that each institution that has been denied admission to membership on the basis of the previous policy be advised of the Board's action and c-Aven an opportunity to file an appli cation for membership if it desires to do so. Carried unanimously, and counsel was requested to prepare the necessary letters to the Federal reserve agents. Szymczak moved that the City Bank Farmers .rust Company be advised throwh the Feder al Reserve Agent at hew York that the Board is willing to consider an application from the trust compa ny for manbership in the Federal Reserve System but has decided not to waive the standard conditions of membership numbered 12, 17 and 18. Carried unanimously. In ti°11/ that, connection with the discussion of the above motion, atten- called to the fact that condi tions numbered 12 and 17 state e4cept with the permission of the Federal Reserve Board, an ETbark shall not take any of the actions referred to therein .411c1 it 78-s understood that while the Board mould not be willing to or amend conditions numbered 12 and 18, action on Yr. 6zy2Thczak's raotion was not to affect in any ray the consideration of a request froz t he f - -rust company under condition numbe red 17 for permission to tlin€,"10 4k,rust fullds for investment in pools of mortgage bonds or other e13.ritiese Mr. Miller referred to the fact that if the City Balk Farmers "113411Y is to be admitted to membership before June 16, 1934, 5/31/34 -9- it will be necessary to take prompt action to develop the information riecessarY in connection with the consideration of the application and it Me understood that the Division of Examinations would discuss 'With 11r. Case the matter of obtaining the necessary additional infor414ticm. kr. Leonard pointed out that the affairs of the trust company vielie given a thorough examination under date of March 31, 1934, but that the examiners did not look into the detailed administration of the various trusts handled by the trust company. The suggestion was made that any further examination of the trust 00Mpany should develop (1) whether any of the funds of the trusts 11414alistered by the trust company have been invested in the stock of the National City Bank and, if so, when the stock was acquired and at 17114t Price, (2) the details of the transaction whereby the National CitY Beak in 1929 acquired the stock of the City Bank Farmers Trust C(1111Y alld (3) whether the affiliation with the National City Bank 48 had anY unfavorable influences on the policies of the trust corn.z i nvesting trust funds. It Was understood that the Division of Examinat.ions mould take up with hr. Case the question of developing this information. The Board then considered and acted upon the following natters: Letter 1,o Mr. Peyton, Federal Reserve Agent at the Federal Reof Linneapolis, reading as follows: r_ "1.i,eceipt is acknowledged of your letter of May 21, 1934, the recapitalization program of The State Savings Bank Of E5 E%anaba, Michigan. You state that the question has arisen as to whether it 'Ilk be advisable for the bank to take out a new charter in the 1602 5/31/34 -10"process of reorganiza tion, thus eliminating all double liability, and in this connection you ask wheth er you are in a position to assure the bank that it may continue as a member of the Federal Reserve System after a reorganization in which a new charter is i&sued and the common stock issue d under the new charter is mithout the doubl e liability. the membership of any State member bank neces sarily termintec when its corporate exist ence ceases, and in the event that 4t 1-8 planned to have the present bank succeeded by a newly chartered institution, the new bank would have to apply for admission to membership in the System. Such application, however, can be Inade by the present bank on behalf of the new bank, to become effect ive on the openin of the successor institution. In States 'where nonasses ssble lawfu stock may lly issue be the d, Board does not requi re that the capital stock of State banks admitted to .2 elabership be subject to asses sment. In this connection your at_ention is called to the Board's letter of Aufws t 30, 1933, .4-7566. "AccordiLg to your letter, the bank apparently proposes to 3,:.sue only ,,90,000 preferred stock to the Reconstruction Finance j u rporation, althoucJi the Corporation has agreed to purchase such in an anount up to ;100,000. he Board is stron;ly of The /14J-I'llion that any recap italization program should:, whenever pos1,1)1e, Provide an amount of sound capital altogether adequ ate in .elation to the bank' liabi s lities. It is assumed that the recapprogram will be expedited as much as possible in order the bank may make the necessary eliminations of depreciation , securities and estimated losses in other assets. If a new tank to be organ ized to succeed the present institution, please adho Board wheth er you contemplate making a new examination bank or whether you recommend that consideration of the I'leation he based upon the repor t of examination as of January 20, 1934. t,e :The report of examination reflects several criticisms of perations of the trust department. Although the department duerall, prope r records should be kept and the operations coninere in a manner above criticism. It is noted that your examLelieves that the bank will effect improvemen ts in this re- a Approved. Reserve Letter to Mr. Williams, Federal Reserve Arent at the Federal ailk of Cleveland, reading as follows: "Referenceismad e to netclier'sletter—of Larch 24 and 14Y 21 Of l,1 2 1934, and their inclosures, in regar d to the application ""le Peoples National BrAnk of Tarentum', Tarentum, Pennsylvania, iCb 4-) .11..0z;t3 5/31/34 -II- for permission to exercise full fiduciary powers. "Consideration has been given this application, and it has been noted that, while the bank's board of directors authorized the filing of the application, there appears to be a wide diverF;ence of opinion among the members of such board as to the desirability of the bank operatinr, a trust department, and that a majority of the directors either definitely oppose such action or are reluctant to have the bank assume trust functions. It has been noted also that the management of the bank is regarded weak by the national examiner; that none of its active ofleers appear competent to handle trust matters; and that apparentlY no arrangements have been made to secure the services of a competent and experienced trust officer in the event that trust powers should be granted. "In el your view of these conditions, and the adverse recommendation executive committee, the Board is unwillinr to take any adction on the pending application unless or until it receives b6fillite assurances that the board of directors of the applicant jnk is sincerely desirous of receiving trust powers, and that alr : iMItc ses of an eyperienced and competent trust officer are The board will be pleased to reconsider the pending,applicaV.on whenever the existing situaticn is cleared up and your execucormittee is prepared to make a favorable recomrendation. " a advise the applicant bank accordingly." Approved. Letter to Lr. O'Connor, Comptroller of the Currency, reading as follows; ofaccordance with the recomrendation of Acting Comptroller d' t..e Currency Await, the Federal Reserve Board approves a re113c . 1111,tte , common capital stock of the 'First National Bank Spirit Lake, Iowa, from ,50,000 to %$5,000, puri, 1,!11/ 1 Lo a plan which provides that the bank's capital shall be 8T.reased , 50,000 of preferred stock to be sold to the ReconY r4uctien Finaace Corporation and/for others, and that the . ,!'oed capital, a portion of the bank's. surplus and undiviced Profit rts i.F.84(el accounts, and a voluntary contribution of zr3,000 to be locally, shall be used to eliminate unsatisfactory assets amunt of approximate1y61,600, all as set forth in Lir. 47aitt s memorandum of Lay 22, 1934." 1 Approved. Letter to La-. 0 Conner, Comptroller of the Currency, reading ollanz: 5/31/34 itIn accordance with the recommendation of Acting Comptroller of the Currency Await, the FederL1 Reserve Board approves a reduction in the common capital stock of 'The First National Bank of B eardstown', Beardstoun, Illinois, from ,;100,000 to ;25,000, Pursuant to a plan which provides for the sale of si75,000 of preferred stock to the Reconstruction Finance Corporation, and for the use of the released capital, to,7ether with a local contributi°11 °f Y39,200 and a portion of the bank's surplus and undivided Profits, to eliminate unsatisfactory assets totalinp; approximately U42,000, all as set forth in Mr. Awalt's memorandum of May 22, 1934." Approved. Lemorandun dated ;,ay 23, 1934, from Er. Smead, Chief of the 1)ivis 1°11 of Bank Operations, stating that replies to the Board's teleC)f with the - ,413r 4, 1934, regarding the cost of telegrams sent in connection Board's inquiry as to the need for credit for the purpose of working capital for ,c) . tablished industrial and commercial bsii:osaes, indicate that seven of the Federal reserve banks paid for the telegrams at commercial rates; that three others paid for them at Governme nt rates; that the as yet unpaid Cleveland and San Francisco bills were also calculated at the Government rate; and that, inasmuch ao the tel egrarris were sent at the request of the Federal Reserve Board Et% represent Board business, it would seem that they should all be Paid by the Board at the Government rate. The memorandum stated also that the difference between the Government rate and the commercial rate On the telegrams Paid by the seven banks amounts to somethin over 4,000 and that, in order that this savinc may be effected, it is recctatended that the telegrams attached to the meriorandum be sent to the ederal Serve bank5. Approved. 1805 5/31/34 Letter to 4,r. Curtiss, Federal Reserve Agent at the Federal Resere Bank of Boston, readirr; as follows: "Consideration has been p:iven to your letter of Lay 22, 1934, inclosinc a copy of a letter written to you by ir. Pliney Jawell on behalf of Coffin L Burr, Incorporated, dealers in securities, of Boston, Massachusetts, and presenting questions as to whether certain transactions fall within the provisions of Section 21(a) of the Lonking Act of 1933. You state that you have in mind the position taken in the Board's letter of December 16, 1933 (X-7729), but that if the Board would like more complete information in de to pass upon the questions presented or in order to refer nZ 7.0the Attorney General you will endeavor to obtain it from (Jr Z "-line the Federal Reserve Board will be glad to transmit a e()PY of Mr. Jewell's letter on this subject to the Attorney denif Lr. Jewell should so request, it feels for the reasons Ze ' forth in its letter of December 16, 1933, that it would not aPpropriete for it to undertake to express opinions upon quesclons of this kind." Approved. Lemorandum dated May 23, 1934 from hr. DuBois, Assistant Co submittinr;,for the consideration of the Board, a draft of a letter to Ir. McClure, Federal Reserve A-ent at Kansas City, reading polloviz: ahis refers to J,r. LcAalms' letter of 1:,ay 13, 1533, inclosassumption of liability' certificates issued by the National illrety C orporation of Law York covering the bonds executed with ,1/3 National Surety Company of New York, by Er. McAdams, as Ase tjs,tant Federal Reserve Agent, and Lessrs. T. Gordon Sanders, Jones and Janes C. Clark, Jr., as Acting Assistant Federal L,c;e flrlie k.ents, of the Federal Reserve Bank of Kansas City. Mr. asks to be advised whether further action on the part of the gentlemen insured is necessary in the circumstances* bon," ince it appeared that it might be advisable to have new teer141:I:=d1 : each of the cases above referred to, this matmith the Surety Bond Section of the Treasury ae cillsrtIllent and the Board vas furnished with a circular letter Act:°esed under date of August 19, 1933, by Er. Thomas Hewes, '11-1, S and indeecretary of the Treasury, to the heads of the departments Pendent ectablishnents of the Government. A copy of L. letter is inclosed herewith. In view of all of the p ' V 1666 -14circumstances set forth therein, particularly the advice conIn the next to the last paragraph and the fact that the bonds mentioned above are not includ ed in the list of excepted bonds referred to, you are advised that it will not be necessary to have Messrs. bander s, Jones and Clark execute new bonds cover1-/IF; them in the capaci described or to take any further action ties in the matter . It is understood that since the date of his letter hr. hehas taken out a new bond, thus making it unnecessary for the Board to answer his question insofar as it relates to his awn bond." The memorandum also stated that hr. Newton, Federal Reserv e Agent at Francisco, whose bond had also been executed with the Nation al Surety Company and liability on nhich had been assumed by the National 811rety Co rporation, had raised the question in a letter dated May 18, ' 17 whether he should renew his bond in some other company, but that ill"Illuch as he had executed a new bond with a different company on thElt * 194, in accordance with the established policy of the Board ends Ice Federal reserve agents should be renewed every four years, vii3uld aPPear that no reply to hr. Newton's letter in necessary. The letter to hr. McClure was approved and it was agreed that it would not be necessary to reply to Mr. Newton's letter. Letter to 12.. Charles C. Pearce, New York, New York, reading 11 follows: "This refers to your letters of April 30 and May 9, 1934, by ':L regard to your request for a copy of the application filed .;".e National City Bank of New York for permission of the Fedthe. lu Reserve Board to establish certain branches in Russia under stj ° r visions of section 25 of the Federal Reserve Act. You you represent a large corporate depositor in the Petro( ;11 uranch of the National City Bank whose account MRS opened a C01) 1. about 6eptember 6, 1917, and that yetir purpose in requesting selle.°f the application in question is to ascertain the reprolens made by the i.ational City Bank to the Federal Reserve .116G7 5A51/31 -15- "Board for the purpose of securing permission to open Russian branches. "Applications made by national banks for permission to establish branches in foreign countries are filed pursuant to the statute as a basis for consideration by the Federal Reserve 1304rd of the question whether in the exercise of the duty placed liPon it by law it should permit such banks to establish the ranches applied for; and, having been submitted to the Board ,or this purpose, it is believed that the information contained in such applications should be regarded as confidential. In Iriel‘r of the confidential nature of such applications and the purPose for Which they are made, the Board does not feel that it Yould be justified in the circumstances in furnishing you with coPY of the application of the National City Bank of New York iLlor permission to establish branches in Russia. It is assumed, 2wever, that you have in mind the possibility of obtaining a of the document in question upon order of a court of coment jurisdiction in appropriate legal proceedings. The Board Tots that it is unable to comply with your request in this and hopes that you will understand the reasons which make eeessary for the Board to take this position." rt Tz Approved. Letter to Ur. Sargent, Assistant Federal Reserve Agent at the Poderal Reserve Bank of San Francisco, reading as follows: "This refers to your letter of Yarch 20, 1934, stating that in receipt of a request from The AngloCalifornia Naf t?usZomtm. of San Francisco for an interpretation of the word as used in Paragraph 'Seventh' of Section 5136 of 440 Revised Statutes. The Federal Reserve Board has not issued iflterpr5jr. or defining the word 'customers' as used watt lq:t or section and feels that it should not undertake to interdefine the word except in connection with the considera,44.11 °f the facts of particular cases. If a case has arisen a State member bank in your district in which the detorminacc n °If , this question is deemed material and you feel, after your ruli:e- has considered the matter, that it is desirable that a be of the Federal Reserve Board be obtained, the Board will g ad to give consideraLion to the matter." You Approved. readi_ Ag Letter to The Central National Bank of Lynn, Massachusetts, as follows: 16(,8 3 5/31/34 -16- "Receipt is acknowlek;ed of your letter of ii.ay 10, 1934, reCarding the application of Fr. Charles A. Collins under Section 32 of the Banking; Act of 1933 for a permit to serve at the same time as a director of The Central National Bank of Lynn, Lynn, L assachusetts, and as officer and senior partner of Collins Breed & Company, Boston, Lassachusetts. the Federal Reserve Board has noted your statement that Mrs Collinn is president of the Lynn Institution for Savings which is the largest owner of stock in The Central National Bank of Lynn and has considered the fact that Fr. Collins is a valuable direct0. of your bank. The action of the Board in denying Lr. Collins' applicaOI1 vas under en interpretation of the Banking Act of 19'33 .lich has been applied consistently with respect to all applicai l°rs of the same general type as his and it does not appear -chat it would be possible to make an exception in his case which ld not involve a reversal of the Board's action in the case 0.1 other applications of the same kind." r Approved. Letter to L. Case, Federal Reserve Agent at the Federal Resel-sre .Lank of New York, reading as follows: "ihe Federal Reserve Board has given consideration to the !-PPlicaticn of Li.. John L. O'Brien under Section 32 of the Larket of 1933 for a permit to serve at the sane time as a di11;ector of the Plattsburg National Bank & Trust Company, nettsel; f re3 'New York, and as a general partner of Parker, McElroy Aabany, , New York. "It a co • appears that the firm of Parker, :,cElroy c company is rilmlsalon brokerare house, the bulk of whose business is in .4.(3ekc arid bonds and that it does not participate in pool operatecljs or the underwriting of securities. However, in its answer th,:11?!ti°21 1, on Federal Reserve Board Form 99c, the firm states 4--L carries narrin accounts and the statement of the firm in Indicates that such accounts may constitute a substan.L-1 f°rIn portion of its business. 'Althoutt the firm of Parker, McElroy 6: Company apparently atial, ' engaged in the business of purchasing, selling, or negotishi securities within the meanirv- of Section 32, the relationcitt involved appear to be of the type that Section 8A. of the reei cI" Act wlas designed to terminate. In this connection, (4,:.;TICe is made to the Board's letters of Lecember 22, 1933 IT1) and April 30, 1934 (X-7884). that .Accordingly, it is suggested that you advise the applicant an (3eticn CA of the Clayton Act is applicable to the relaticnv described in the first paragraph of this letter, and that 5/31/34 -17"the Board would be unable to find that it would be not incom.Patible with the public interest to issue him a permit under the Clayton Act covering such relationship. "It will be appreciated if you will advise the Board what steps the applicant intends to take in order to brinn; such relationship into conformity with the requirements of the Clayton Azt.n Approved. Letter to 1,:r. M. H. Rorick, Toledo, Ohio, reading as follows: A "The prj 30, Federal Reserve Board has received your letter of 1934 regarding your application under Section 32 of Bankinr, Act of 1933 for a permit to serve at the same time 48 a director of The Fayette State Savings Bank, Fayette, said as Ohio, , a J;enerul partner of Spitzer-orick & Co., Toledo, Ohio. Your statement is noted to the effect that Spitzer-Rorick Cc" is now in liquidation, but that an Ohio corporation under the name of Spitzer-Rorick & Co., Inc. has been organized to fY on the securities business formerly engaged in by the V Liner 1,; and that you are an officer and director of the corporaZr-oln. "The action of the Board in your case was under an interle)1etati°n of the Banking Act of 1933 which has been applied e;nsistently with respect to all applications of the same gentYPe as yours and it does not appear that it would be posa e t° make an exception in your case which would not involve sfietil Z -c r :alacii r2 "action in the case of all other applieIs r T 7 Approved. Letters to L.r. Case, Federal R0serve Agent at the Federal Reof Ilew York, referrin,,; , to the following applications for 13"tlits urlder section 32 of the Bankin: Act of 1933, and c stating in Ilse that, in view of the orinciples of stated in the Board's letter April J. 13, 1934 (X-7860 1411040,a ) , it appears that the dealer in securities sho Id not be regarded as engaged primarily in the Of business Plarchtt serve B Of sellinor nepotiating securities within the meaning oect4 32; that, therefore, a permit covering the relationship 5,51/%54 described in the application is not necessary; and that, accordin unless there are other facts which the agent believes should be called t0 the attention of the Board, it is sugfP,ested that he so advise the a Pplicant s Mr. Henry Bull, for permission to serve at the same time as a director of the Fulton Trust Company of New York and as a Partner of Harriman and Company, both of New York, New York. Charles E. Haydock, for permission to serve at the same time as a director of the Northern '.'estohester Bank, Katonah, New Y°rk, and as a partner of Parker, McElroy and Company, New York, liew York. Approved. Letl-ers to the following applicants for permits under section 32 °I' the Banking Act of 1933; each letter stating that it appears that the re lationship covered by the application is mithin the class 71111-eh section 32 Was desiTned to terminate, and that, accordinay, th ard is unable to find that it would not be incompatible with the Public interest as declared by the Congress to grant the application, although in the event the applicant desires to submit further tacta or argument in support of the application the Board is proPaled to give them careful consideration: L;r. F rederick C. Peach, for permission to serve at the same time a director of The PiLtsfield-Third National Bank and Trust 411113111 , and as manager of G. M.-P. Murphy &, Co., (Pittsfield anch both of Pittsfield, Massachusetts. Lr. c leorn:e Baron, for permission to serve at the same time Z,a_ea d irector of the Security Trust Company, as a director of BL Citizens Lutual Trust Company, and as a partner in jeo. ' Q14:Qn & Company, all of ;:heeling, West Virginia. Approved. 5/31/34 Letters to applicants for permits under the Clayton Act, adof approval of their applications as follows: " L J. L. Beck, for permission to serve at the same time as a cirector and officer of The Rock County i;ational Bank of Janes7111e, Janesville, wisconsin, and as a director and officer of the Rock County Savings (1; Trust Company, Janesville, Wisconsin. 14:. H. H. ci rector Bliss, for permission to serve at the same time as a of he Rock County National Bank of Janesville, Janes-91e, :dsconsin, and as a director of the Rock Count,..y Savinss L,'rust Company, Janesville, Wisconsin. P vo Si Jackman, for permission to serve at the same time as director and officer of The Rock County National Bank of .(.1,ansville, Janesville, :dsconsin, and as a director of the County Savings & Trust Company, Janesville, Wisconsin. F. H. Jackman, for permission to serve at the same time as a.director and officer of The Itock County National Bank of Jamesthe$ , anenville, Wisconsin, and as a director and officer of Rock County Savings & Trust Company, Janesville, Wisconsin. 4" LeVicar, for permission to serve at the sume time 11,.8 a director of The Rock County National hank of Janesville, isconsin, and as a director of the Rock County Savg8 arust Company, Janesville, Wisconsin. 1,1r, n2 ' 41°InaS S. (3 a director Nolan, for permission to serve at the same time and officer of The Rock County National Bank of C:11637il1e 'Janesville, ';dsconsin, and as a director of the Rock untY sravins & Trust Company, Janesville, Wisconsin. Lr. J w o L dire t . -ivilcox, for permission to serve at the same time as a or of The Rock County National Bank of Janesville, Janes,,, T2, “isconsin, and as a director of the Rock County Savings 4118t Company, Janeavilie, ..isconsin. Approved. Thereupon the meeting adjourned. Approved: Govern° •