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3047 meeting of the _!;xecutive uommittee of the l'ederal Reserve 41z1-_ was held in Washington on Tuesday, October 2, 1934, at 3:00 p. PRESENT: Mr. Thomas, -Vice Governor Yr. Tames Szymczak Bethea, Assistant Secretary Mr. Carpenter, Assistant Secretary The Committee considered and acted upon the following matters: 1:eillorandum dated September 29, 1934, from Yr. Goldenweiser, 14ector of the Division of Research and Statistics, stating that, at t44"ing or the System Committee on Legislative Program on September : Z4)19344. ' the Committee "authorized the technical staff to obtain such AID 48 might be necessary for accompliAhing its work expeditiously"; th4t it is s aticipated at this time that the additional services required 1114 be 04e o, two junior assistants and two stenographers, bringing the t°tq e4Pellses of the Committee, including the salary ofr. Stark, tillaie41- as sistant to the committee, to an amount not to exceed ,-;2,000 1().11th; azd that it is recommended that the action of the System ComO kitteeLe gislative Program be approved by the Board, with the under4141144g that the expense involved will be prorated among the twelve Iklerea reserve banks in the msnner recently approved by the Board with 4:1'cit0 Dolt the tt0 salarY of Mr. Stark, who has been designated Secretary of The memorandum also recommended, in accordance with the J411 rrererred to above, the appointment of Mr. Martin Krost as a tzt: 4aaistaa.t on a month-to-month basis, with salary at the rate of 4.1 toilth, and of Mrs. Astrid L. Donaldson as a stenographer, with 411 411t the rate of 135 a month, both effective as of the dates upon )14e14Mr. zrost and Mrs. Donaldson eater upon the performance of their 3048 -2- Approved. (3 e Telegram to Yr. Walsh, Federal Reserve Agent at the Federal ReBank or Dallas, reading as follows: eon "Your letter September 8 re services of T. W. Royall. Board hi ellre in opinion that national bank should be reimbursed for b,s,„salarY and approves reimbursement at rate of salary received as stated your letter." Approved. Telegrain to Mr. walsh, Federal Reserve Agent at the .bederal Reax of Dallas, reading as follows: by "Y°ur letter September 8 re reimbursement for services rendered I‘:e.rsh. While sympathetic with position taken by your directors, Oa laird b elieves it not in harmony with spirit of law for members of peal ,nial advisory committee to act also as representative of reserve bank. Therefore, any payment to member of committee 44-Lot be in accordance with provisions of law in connection with neceiees rendered as member of committee; i.e., reimbursement for die14.8841rY expenses while engaged in business of committee or per a4oe all°wance in lieu thereof. Services are not limited to attendroxiin meetin cs of committee, but may include any services peras member of committee." -4L4lic Approved. Letter to i4x. Case, Federal Reserve Agent at the Federal Reserve xew York, reading as follows: 4:0tis Jeotio,is to advise you that the Board will interpose no. obBiltrA, ' 4 40 the absorption by The Marine Trust Company of Buffalo, rilerc ; 4°) New York, of the Bank of Snyder, Snyder, New York, through thtlt subject to condition numbered 2 below, provided, of course, leetac°11118e1 for the Federal Reserve Bank is satisfied as to the ault iaspect of the transaction and that the merger will not reCokmp 4 411Y cha Age in the corporate existence of The Marine Trust 841d th °I 'Buffalo which will affect its status as a member bank, 4iti the appropriate State authorities approve the merger. °I' The T,,e comPtroller of the Currency has approved the application '441'ille Trust Company of Buffalo to establish a branch at 3049 "SaYder, subject to the following conditions: 1. The establishment and operation of a branch at Snyder, New York, by The Marine Trust Company of Buffalo, shall be approved by the approDriate State authorities; and 2. n 4 '-r-Lor to the establishment of the branch at Snyder, New York, and the absorption of the Bank of Snyder, Snyder, New York, incident thereto, the Bank of Snyder Shall, if it has not already done so, charge off or otherwise eliminate estimated losses of 6,400, doubtful assets aCgregating a6,251 and securities depreciation of .:20,320, all as shown in the report of eImmination of the Bank of Snyder as of May 2, 1934, made by an examiner for the New York State Banking Department, and any other known losses, and depreciation in securities. alltaln:hc Board has granted and transmitted in the usual manner, to e----LtY for the issuance of the necessary limited voting permit or Therlable Marine Midland Corporation to vote the stock owned by it ' l!arine Trust Company of Buffalo to effect the proposed merger." Approved. Letter to L. Ilederal Reserve Agent at the .iederal rite t Of Cleveland, reading as follows: TNst"Reference is made to the report of examination of 'Phe Toledo raexite- ,,,. C°111 ,PallY') Toledo, Ohio, as of Larch 23, 1934, and the supplesubmitted in connection therewith. s"11 transmittinc the report, Er. Fletcher advised that losses e t this Irtlated had been chared out or amply covered by reserves. In ciati(: c ,4; lection, the Board feels that estimated losses and deprethe ---, .Listed for elimination have not been properly eliminated by tal entt111. up of reserves which are included with the bark's capitlaed—counts in its published statements. Such reserves should be Pl'eci her in making charge-offs of the estimated losses and deeJad ci: -L°11 listed for elimination or treated as valuation reserves ej:Llleted from the respective asset accounts, showing only the 14 thA-114t2 or the gross amount of such assets less the reserves, the c; DlIblished statements. Any reserves for losses included with tiohe 11.!'tal accounts, therefore, should represent merely alloca! ()4t1: 4 2 34rPlus and/or undivided profits to cover possible or “)z. coz!lat losses; or, in other words, represent true 'reserves ' 61116e4cies.' 1.10,9 nhas been noted that investments of trust funds included ''4) certificates of participation in mortgage loans and 3050 10/2/34 -4hat Only ticipation 4 per cent interest is paid on the certificates of parwhile 6 per cent interest is charged on the ,underlying : a t6:, agss.•The Board would like to be advised if the interest au accruing to the bank is permitted, either by valid agreeto-7, appropriate court authority. The Board would also like ths ' e advised if the mortgages, as would appear from comments in 0_, .1port of examination, have been purchased from the bank. ZI:dealinc violates the fundamental principles of trusteeship, is sc doing a bank may incur heavy legal liability, especially con : ,his true when the bank profits by the transaction. In this via-s—?ction the Statement of ,rinciples of Trust Institutions which follincorporated in the Bankers Code of Fair Competition has the J-owing comments: i3 a fundamental principle that a trustee should not have j7Y personal financial interest, direct or indirect, in the .rust i nvestments, bought for or sold to the trusts of which it is trustee, and that it should not purchase for itself any inlrities or other property from any of its trusts. Accorao-g-LY) it follows that a trust institution should not buy for tr .16111 to its estates or trusts any securities or other properiY -- which it, or its affiliate, has any personal financial 4tereet ) and should not purchase for itself, or its affiliate, Y securities or other Property from its estates or trusts.' ber "It has been noted also that a trust, designated as trust numfroms:: : 7entY-nine, was created in November, 1924, by the transfer that !'r hsakin,%. department of dormant individual accounts and ti.04 , u has been the practice to transfer, from time to time, addiaccounts to this the trust. On the date of the examination, a ,nt accounts aRai4 carried in this manner totaled ,98,469, /thich the trust department held investments with a book value , rihathe°'• 4104,390, and a market value of A8,845. Deposit accounts, r '4c1 the active or dormant, are, of course, liabilities of the bank kethorl assets or the trust are the property of the bank. The carrying such accounts is unsatisfactory inasmuch as the the is not .41own on the bank's books and published statements, kti;;;°1111t cf such deposits is not taken into consideration in com! laY4i!2serves, and no consideration is given to any loss which -cherei: 0-6 in the assets of the trust. It will be appreciated, "colibrh-r'e, if You will reouest the bank to transfer these dormant Ze/it; 17,3 and the etat:ers they assets or the trusts back to the banking departmay be properly shown on the bank's books and ballk.;e4t2' and advise the Board as to the action taken by the Approved. tetter dated October 1, 1934, approved by three members of the 3051 10/2/34 -5Ik'ard) to Mr. Newton, Federal eserve Agent at the Federal P,eserve 111111c °I' Atlanta, with regard to the matters commented on in the re13°11 °I' exataination of "The Birmingham Trust and Savings Company", kr4illighani) Alabama, as of February 12, 1934. Approved. Letter 4-vo L'Ir. Stevens, Federal ileserve Agent at the Federal Bellk or Chicago, reading as follows: itm "Reference is made to your letter of September 7, 1934, '"ing the application of 'The Knisely National Bank of Buttia Butler) Indiana, for permission to exercise limited --11e4arY powers. "Ill accordance with the recommendation of your to executive -ulittee) in which the Comptroller or the Currency concurs, the will defer action on the pending application until an exambY national bank examiner has been completed and a rethe Ciel'eor is available, at which time it will be glad to have y further recommendation you may wish to mnke 14 th:Tiati:fesr to th"It has been noted from your letter and other data submitted or t ; e 11 B°ard relative to the pending application that the amount st business available from the predecessor bank is very 43411 elid • a voilm, it appears to be auestionable if the bank could develop 44d, -"4e of riduciary business sufficient to justify the expense ilielat-esponsibility incident to the operation of a trust departyou • It 13 succested, however, that if it is possible to do so to Your trust examiner visit the applicant bank at or prior as ru7l tinle it is examined by a national bank examiner to develop cAlaii;:;" inabrmation as Possible relative to the experience and Prop.:, ° ,ati°ns or the proposed trust officer, members of the 1410 6- u- trust committee, and legal counsel, to supplement the rormaZ.statements in that regard, and to furnish any other inBoara ;.°11 which in his opinion would be of assistance to the bY th,-a collsidering the application subsequent to an examination cliseu;Iltional examiner. At the same time your examiner should sibiii.with the bank's board or directors the duties and respontho les incident to the exercise of trust functions, with the to wit;in raina that after due consideration, they may decide 'Idraw their application." Approved. tetter to Iiir. O'Connor, Comptroller or the Currency, reading as 3052 -6- "In accordance with your recoIrmendation, the Federal : , .eserve oearcl aPProves a reduction in the common capital stock of 'The to7/118end lational Bank', Townsend, Lassachusetts, from Q10°,000 ca 45)000, pursuant to a plan which provides that the bank's _Ptel shall be increased by 275,000 of preferred stock to be a- to the Reconstruction Finance Corporation and/or others, 1)1,0 that the released capital, together with the bank's undivided 13 rits and such portion of its surplus as may be necessary, shall Used to reduce the book values of lower grade securities to present market values, all as set forth in your memorandum of iptedoer 17, 1934. "This approval supersedes the Board's approval of 1, 1934, (4- the . °ricinal pinn of capital reduction." Z Approved. Letter t - 0 L'Ir. O'Connor, Comptroller of the Currency, readin toiaole: as toar "In accordance with your recommendation, the Federal eserve wiltd aPProves a reduction in the common capital stock of 'The 650 °A Ilatiwial Bank', Wilton, New Hampshire, from ,100,000 to , Pursuant to a plan which provides for the use of the released least (1 capital Capital in eliminating a corresponding amount of the de lo8s,,„ assets in the bank, including the estimated videZ8 and all depreciation in lower grade securities, and proalSO for the Payment of the David whiting loan of 5,0°0 it _r o to the reduction in common capital stock, all as set forth Y Ur memorandum of September 17,1934." Approved. to Letter to La.. O'Connor, Comptroller of the Currency, reading as 193e1 "1 ,!?!elPt is acknowledged of your memorandum of September: 26, sto4 "4.6h reference to the proposed reduction in common capital , 01' 'The National Bank of Coxsackie', Coxsackie, New York, to th 4.00,000 to ;,50,000, and sale of 450,000 of preferred stock the Be ilaconstrucion Finance Corporation, which was approved by °ard on Slily 31, 1934. (lerae 011 advise that the Reconstruction Finance Corporation has alga to Purchase only .:25,000 of preferred stock of this bank, eaDitTillnlend that the bank be permitted to reduce its common erilenc14- 48 °riCinally proposed but that the plan as a_yproved be to , to Permit that theamount of preferred stock to be sold the "econstruction Finance Corporation be re, uced from .50,000 3053 10/2/34 -7"to 25,000. "Inasmuch as the released capital, together with a portion of e_ bank t s undivided profits, is to be used to eliminate all es- . ted losses and depreciation in investment securities as class).fled 193 bY the examiner in his report of examination as of August 1, ti 4 and the adjusted capital structure will be adeouate in relas,°4 to the deposit liability, and since a comparison of the irteMents of condition as of February 27, 1934, and August 1, th343 discloses an improvement in the bank's general condition, in accordance with your recommendation, amends its etn.°113 approval to provide for the sale of :A5,000 of preferred eti'instead l of 050,000 as originally planned, with the underd ing that the other provisions of the plan as set forth in -. wit's memorandum oi July 18, 1934, remain unchanged." th Approved. Letter to Lr. O'Connor, Comptroller of the Currency, reading as follows: rec "14 accordance with Acting Comptroller of the Currency walt's endation, the Federal Reserve Board approves a the reduction in AnaCnZon capital stock of 'The First ITational Bank of Anadarko', Oklahoma, from cl50,000 to 30,000, pursuant to a plan c'$20— 'Provides that the bank's capital shall be increased by 0014(100 of preferred stock to be sold to the Reconstruction Finance 4 and that the released capital shall be used to eliminate to abiefactorY assets in the amount of approximately 48,659 and allangment the bank's surplus account by approximately c)1,341, "set forth in Er. .Zwalt's memorandum of August 6, 1934. it caa considering the plan under which the proposed reduction eriti4'"al is to be effected, it has been noted that your examiner 'pelt cized the bank's management as incompetent, indolent, and 1133 d ishonest and cited certain transactionswhich involved that je crtminal violations of law. It is understood, however, tIon ,70 Manacement problem in this bank is receiving the attenke4t YoUr office, and that a report has been made to the Departviol Xtistice with respect to the transactions involving possible , O law." poasZ Approved. Letter ' t 1%17 to Lir. York, Case, iederal Reserve Agent at the Federal Reserve reading as follows: laleta" tilfereace is made to 2.:r. Dillistin's letters of September 17, - and April 25, 1934, and to your letter of August 7, 1934, 3054 10/2/34 -8b "relative to the application of Union County Trust Company, Elizae New Jersey, for permission to vote the stock which it owns c ontrols of The First National Bank of Cranford, Cranford, New 08 j2Y, for the voluntary liquidation of that bank as an incident t "s absorption by Union County Trust Company and the operation 4 the latter of a branch at the present office of The First Na°nal Bank or Cranford. ."The report of examination of Union County Trust Company as of 11 30) 1934, made by an examiner for the Federal Deposit Insurt: C°rPoration, indicated that the bank had a total capital strucde 8 c)f 1,5?6,400, in addition to which directors, subordinated eairsits amounted to „:300,000. The report showed losses in loans n°ther assets of ;1,761,500, net depreciation in securities of ri;j ! 1 6 ' 8°07 and doubtful assets of :-;422,300. On the basis of these '" and after considering the subordinated deposits of directors del:7' Part or the capital structure, the bank would have a capital Were :930,900. If doubtful assets amounting to 422,300 tio "educted, the capital deficit would be ',A,353,200. In addidep' the report showed the bank had „;3,167,600 of slow assets and Per sits °I ' C2,308,500. Cash and securities amounted to only 28 cent of total deposits. _ "The repo on3f , examination of Union Coty of County Trust Company as ctober made by an examiner for the Federal Deposit colijrTice Corporation, showed a capital deficit of ;906,000, after Part-':rinC the directors' subordinated deposits of .J300,000 as a the aZtl tiltle4a1: 0 11Ar .uoture and not deducting doubtful assets in : tioria7hs latest available report of examination of The First Nabalik Bank of Cranford as of August 2, 1934, made by a national 8seurri ainer, showed losses of A.10,200 and net depreciation in C48,000, as compared with a total book capital strucdoubti,-1 -436,600, or capital deficit of :21,600, not deuctingoh er 11I\TJ- assets of :75,800. ;Ls a protection to depositors the Gove ti°nal Bank Examiner at New York was holding 450,000 of stoeki-1-11t bonds pledged by Union County Trust Company (the chief to Th (4der) as a condition precedent to the granting or a license holta :PIrst National Bank of uranford to reopen after the banking )aet 1)1.1r• Considering this guaranty, it appears that there is a Ilatiolisotion of ,122,600 to the deposits of ,768,400 in The First Balik of Cranford, after eliminating all losses, net de8 , " - °11 and all assets classified as doubtful. Cash and marketamounted to 75 per cent of total deposits in the c)11&11 IN bank. 174e i th la% Dillistints letter of ,:eptember 17, 1934, there O IJniL(3,,ed a coPy of a letter to you from R. S. Douglas, Treasurer 4tated -7,`1°11ntY Trust Company, dated August 24, 1934, in which it was tube hat the bank had consummated changes an in its capital struci7. her Q4 ' 8 ' 88A,, euY the capital is now represented by the following three -Q of stock: 3055 -9"Preferred stock TAt Preferred stock 'B' Common stock l,000,000 450,000 300,000 thislk/ tuglae' letter also contained a request for the issuance, at com, ime, of a general permit in order that Union County Trust meZellY maY vote its stock and thereby make possible the consumcertain plans which the board of directors of The First "nal Bank of Cranford have under consideration. 'Inasmuch as the latest available examination reports or the 1ject banks and the information rurnished in L. Douglas' letter tiollUgust 24, 1934 indicate that the depositors of The First NaBank 0r Cranford are in a better position now than they oe were deposit liabilities assumed by the trust company, Itohe Co mptroller's office has not indicated its approval of the posi;r?P°sad plan of Union County Trust company to assume the debilities and the assets of The First National Bank of 130;"1.°I'd and operate a branch in Cranford, the Board is not disvo, ed t° it a limited permit to Union County 1:rust Company to orl sto„ Stock - owned or controlled by it in The First rational Bank to nn4r°rd for the pur-Jose of consummating the plans above referred or more specifically detailed in L:r. Whittemore's letter to you 4111 9) 1934, the : The Board's ANCIGAR telegram of January 6, 1034, authorizing coAt,?stlanee of a limited permit to Union County Trust Company, qined the following language: 'You should advise applicant and each of its subsidla n1,7 member banks that on the basis of information availZILes the Federal Reserve Board feels that as a condition Precedent to the granting of a general voting permit, aptot t and its subsidiary member banks will be required strengthen their respective capital structures and--ueriallY los to1, carge off or otherwise eliminate such estimated the : : e and such estimated depreciation in securities, other ree„-,,:141°ea in the four highest grades as classified by a ga,;r4zed investment service orc;anization regularly enMa;-- in the business of rating and grading securities, as ”1„aPpear fram current examinations of such banks.' 1 1". Douglas' letter it is apparent that he considers that the: co °111 ; are 8t1on3 which have been effected by the banks in this group 13receVicient to comply with the i3oard's requirements as conditions aet roent to the issuance of general voting permits. From the facts has Made Isth above it does not appear that union county Trust Company eZtellt ti„oorrections rehabilitated its capital structure to such and that eral the Board wouldfeel justified in issuins to it a cent flai/1 1.%!;11 Permit. In this connection, you are requested to ascer'etaiir-- union County Trust Company, and advise the Board, the the ITE:ii Y the corrections which have been made and the amounts of -"us classes of criticized assets which are still carried 841 3056 1w2/34 -10;:4 the books of Union County Trust Company and The First Dational ein! of Cranford, as well as linden Trust Company, another sub01 TT 4 twirMatiOnla2 unty Trust Company. Upon receipt of this inthe will Give further consideration to the applicafor the purpose of determining conditions under which a limited Perrait may be issued at this time authorizing the holding sub4""Y affiliate to vote the stock owned or controlled by it of its istiliSldlarys member banks for the election of directors and transactof a routine nature at the next annual meetings of the reholders of the respective banks. doe "From all of the correspondence in connection with this case it /lee :11°t appear that the holding company affiliate contemplates the ora4sitY of voting the stock of either The First 1,7ational Bank of such °I'd or Linden Trust Company for any other special purposes. If thereofIlecessit should arise, please advise the Board of the details ilece in order that appropriate consideration may be given to the ssarY limited permits. res "Please advise the applicants of the Board's position with Peet to the foregoing matters." Approved. LleMorandum dated September 28, 1934, from Llr. Goldenweiser, krector of the Division of 'Research and Statistics, stating that he had NeiNed a letter from :•1" Leo T. Crowley, Chairman of the Federal DeDoait Insurance Corporation) requesting that he be furnished with a camset of the volumes containing the report of the :ystem Committee cli}3ratich, Group and Chain Banking; that, while a complete set of the l'olitaez is not availa.ble, there could be sent to Er. Crowley a set which N4141 contain two volumes in which Some of the exhibits would be incomlet 134te; '44 that it is recommended that such set be sent for the use of kr 'Crovirley and other executives of the Corporation. Approved. 1)klika Te1e6rEra to the Federal reserve agents at all Federal reserve readille as follows: 4111 resPonse to a number of questions which have arisen in 3057 10/2/34 -11"e°44sct' lon with section 7(a) of T),egulation T, the Board has issued the fcalowing interpT'etationS: "1. The account that may be designated as an old account is the account as it stood at the opening of business on October 1) 1934, with such changes as could have been permitted in such 8.,ccount under section 7(a) of the regulation if the account had been designated as an old account at the beginning of business on October 1, 1934. "2. The creditor may designate such account as an old ccoUnt at any time prior to I]ovember 15, 1934, and may permit Zansactions in the account pending such desicnation; but there not be included in any account designated as an old account transaction which could not have been made in the account t it had been designated as an old account at the beginning of slotexIdzi October 1, 1934, and any transaction which cannot be must be made in or transferred to a new account. After an account has been designated as an old account the r re ire egulation permits the withdrawal of cash or securities only the account is an unrestricted account on October 15 and if "e withdrawal does not make the account a restricted account. 4. If, between the opening of business on Oc-,ober 1, 1934 th- the time of the designation of such account as an old account, ace cre has been any withdrallalof money or securities from the 1,_°11ht, such account cannot be designated as an old account un07, s it is an unrestricted account on October lb or on the date and/or designation, whichever is the later, or unless the cash the/or securities withdrawn from the account are replaced before coount is designated as an old account. If, between the opening of business on October 1, 1934, ;the +4-.le of the designation of such account as an old account, euute has been any additional purchase of securities in the acpure:t °r anY substitution consisting of a sale and replacement Which results in an increase in the adjusted debit :!8 of the account, the securities purchased and any debit ror-as the cost thereof cannot be included in the account designated cad account but may be transferred to a new account. :" Even though transactions have been made in an account subs 184c-Tlent to .::eptember 30, 1934, the creditor may for convenor designate the account exactly as it existed at the beginning on October 1, 1934, as an old account and may transter a 48;"--4 transactions made subsequent to September 30, 1934, to o 87 account, to which also may be transferred any money and/ €140eeellrities lawfully withdrawn from the old account in accordwith section 7(a) of the Regulation." Z 7 Approved. 11411,a) t( lter dated October 1, 1934, approved by three members of the AUstin, Federal Reserve Agent at the Federal Reserve Bank 3058 10/2/34 -12•""adelphia, reading as follows: "This refers to Li.. Hill's letter dated September 7, 1934, recard to the auestion whether the Girard Trust Company, tjjladelphia, ankinP gennsylvania, may treat amounts due to and from prlvate b firms as amounts due to and from banks in cornreserves reouired to be maintained by such member bank the 17 ) ; 1 the Federal Reserve Bank of Philadelphia pursuant to the c)visiclhe of section 19 of the Federal Reserve Act. ruled"Ae stated in Ia.. Hill's letter, the Board has heretofore that Private bankers are not banks within the meaning of s te!°11. ici 13 Of the Federal Reserve Act which provides for the exwas-4°4 0f clearinE privileges to banks. The above ruling, which PUb Sept liehed at page 693 of the Federal Reserve Bulletin for ped ' er, 1917, was based upon the fact that section 1 of the to Reserve Act provides that the word 'bank' shall be held eze,:2'ude 'State bank, banking association, and trust company', a„'IJ4 where other types of banks are specifically referred to, "u s bawcthat uch terms are not ordinarily used to indicate private ers. th"The Board is of the opinion that the word 'banks' as used ih 0th pel,Phrase 'the net difference of amounts due to and from mellk8 ' in section 19 of the Federal Reserve Act does not Ude 1-, 4 4'r-Lvate bankers or private banking firms. rm Accordingly, ZUlts due to and from private bankers or private banking firms be considered as amounts due to and from other banks in reserves under section 19 or the .ederal Reserve Act." Approved. Letter dated October 1, 1934, approved by three members of the to the ecretary or the l'reasury, reading as follows: Eldure"This refers to La'. Opper's memorandum of September 11, 1934, A11 11, 88ed to LI.r. Eorrill and inclosins a copy of a letter dated 1934, addressed to the Secretary of the Treasury by 4e ha ! --'arY of the Interior, in which the latter advises that Veae;-140 a uthority to dispose or the site to be purchased by the 'ieserve Board from the,overnment and can see no reason !,c1111 3,.P ning in executing with the Secretary of the Treasury qlectej1 deed to such property. He advises further, however, 1101114-, lt shoUld be determined that the Secretary of the Interior 4a to ti-,XecUte such a deed in order to avoid any possible question the of the conveyance, he will be glad to do so. the are advised that, after consideration of this matter in 4cler °I' the letter from the Secretary of the Interior, the *Qra t '' eserve board prefers to have, in addition to the deed he Seel'eta;y of the _Teasury, a quit claim deed also from 3059 1W2/34 -13"DePartm pea_ ent of the Interior with respect to the property which the Bi !al Reserve Board will purchase in accordance with Governor th4e4.'s letter of August 193A-, addressed to the Secretary of vullTreaeurY; and it will be appreciated if such quit claim deed be executed and transmitted to the Board when the deed from the of the Treasury is furnished to the Board. In view °rtSeeretarY or xhe Provisions of the Lxecutive Order of the President 2:o. 6160 plAh.111 , 16 10, 1933, and of the Act of Congress approved I:_arch 2, 1034, sho 49) 73d Congress, it would appear that such quit claim deed executed by the I:ational Park oervice thrcugh the agency or thd be e director of such oervice." Approved. Letter dated October 1, 196L.',, approved by three members of the Ulaude 0. Pike, L:ditor of The Jhicago Daily Ilews _amanac, reading as follows: that ;7! . 118 refers to your letter of L;epteml?er 4, 1934, requesting ev sion be i r re made of the tabulation inclosed therewith in gerd 1933. to the branch banking situation in the various states in eoMpla re ply You are advised that the Federal Reserve Board has bEtlik-i---4 no summary of the state laws on the subject of branch 13111)1:% which is available for general distribution since that 6 ce311;:-e , ( 41, °I1 Page 455 of the July 1932 Federal Reserve Bulletin, atatZ Which is inclosed for your further information. The 171.-th'ent inclosed with your letter is in agreement, howevr,liab it is beinformation from unofficial sources and be s ubstantially correct. ciatar,r,L2!szuch, however, as the Board's information is b.a?ed on it is'''44liered from various sources and is in no sense oi-zicial, 141.0 l'.61.cIllested that the Board be not given as the source of : any °I. the 7, °11 on this subject that may be included in the next issue `"licaco Daily News Almanac and Year Book." Approved. Letter to N.1.017a. • dated October 1, 1934, approved by three members of the '.zuY P. Greenwald, Los Angeles, California, reading as t° th"Thi3 refers to o yo your letter of September 1, 1934, in regard 0 -e m, ° ve4y of a proposed loan to the Boulevard -Plaza Angeles, California, under section 13b of the Federal 3060 -14"Reserve Act. "Frontthe information submitted, it is understood that the „ -.1n3allY is engar;ed in the business of subdividing and developing 0 -;'1 estate for home sites. It appears that substantially all del,rie ., loan applied for would be used to pay off existing inaa;!auiless and a small portion thereof would be used 'to provide tonal working capital with which to resume commercial operait. : 48) including additional employment for sale of lots for buildis-2,1 , 1rposes, in conjunction with the new housing program'. It th "uszstood that the company's application has been denied on eZ,gr°und that the loan is not for the purpose of providing the vallY with working capital, as required by law. Boa "As indicated in the statement printed as a preface to the powrd'e Regulation S, the Federal Reserve Board has left the broad 1313%:Jallted by Congress to the Federal reserve banks in section tho,:r."-Y Unimpaired and has prescribed no restrictions beyond de,7 14 the law itself; and, accordingly, it has not attempted to the words 'workinc: capital'. However, a Federal reserve laast °bseTire the requirements made by the statute in granting the.JT0,kations under this law. Congress has seen fit to require Made under this section shall be for the purpose of /nay ;‘,suine working capital and, therefore, a Federal reserve bank conim:°t lawfully make an advance to an established industrial or with-rcial business unless it is for the purpose of providins it w°1114inC, capital, batik:11111e the Federal Reserve Board feels that Federal reserve deteinarily are in a better position than is the Board to collsille questions of this kind, it has, in view of your request, by th '"lered the question whether the loan which has been requested Boarde Zoulevard Plaza Company, on the basis of the facts as the pe:4 17114der t3nds them, is for the purpose of providing such cam3 the p ith 'working capital' within the meaning of section 13b of 411 oreral Reserve Act. In view of the fact that substantially the loaa Ilesa is for the purpose of refunding an existing indebted4o 1,L'Ll in view of the other facts of the case, the Board finds Of sa ; 1804 to differ with the conclusion of the Federal Reserve Bank the euzFrancisco that such loan is not for the purpose of providing 4, 13 tanY with working capital. ,13proanl, is the considered policy of the Federal reserve banks to quedtions of this kina arising under section 13b of the , 3c)kird haResarve Act with a liberal viewpoint and the Federal Reserve n1t 3 ast! lso given this question a sympathetic consideration; "11,cwal; o:"."-licated, it is unable to reach the conclusion, in the 14,07147"ances of the case, that the loan is for the purpose of jaillig the company with 'working capital'. The question is not eciel., resPeot to which either the Federal Reserve Board or the 14 reserve banks have authority to exercise discretion and, eW C/f the requirement which Jongress has prescribed in the 3061 10/2/34 -15" : 11 8 ' 7 I am sure you will appreciate the position which it has been —G88arY for the reserve bank to take in the matter." Approved. Letter to Er. Austin, Federal Reserve Agent at the Federal Rec f Philadelphia, inclosing the following Clayton Act permit; el gestirig that, When transmitting the permit to the applicant, the Nellt advise him that it is with the expectation that he will satis- serve l'Itet°rilY attend directors' meetings of the Eadera bank that the permit b'been cranted; and requesting that, when the agent submits his recameliciEtti°11 as a result of his annual review of the permit, he report 1\111 €18 to the a pp cant's attendance at directors' meetings: , as' a igf-L a. Fenninger, for Permission to serve at the same time ana dlrector of The Eadera National Bank, :,:adera, Pennsylvania, ph„ae an ofricer of the Provident Trust Company of Philadelphia, 4J-adelphia, pennsylvania. Approved. Lett er dated October 1, 1934, approved by four members of the to 1:r. /-clures, Federal Reserve Agent at the Federal Reserve kzlit or tO4ra, ''8113as City, reading as follows: eonsi" a°4 3.111Y 23, 1934, the Board advised you that it had given Llissation to the application of Er. H. R. Riley, Plattsburg, to " for permission under the provisions of the Clayton Act liati-onal -.6 at the same time as director and officer of The First 44d 01.1 .2.4 'nk of Plattsburg, Plattsburg, Eissouri, and as director the bn,'"er of the Bank of Osborn, Osborn, Eissouri, and, upon the b; -4.8 of the information before it, held that the issuance of inte it applied for would be incompatible with the public large,'" T11'-, --d Board's action upon the application was based 11Pon the switching of loans between the two banks and the ertent of the uses Ithich have been made of the credit ,' c't The Iiirst NatiOnal Bank of Plattsburg and the Bank ;Jahlts.°7 as shown in the current reports of examination of these addi llbaecuently, in accordance with ,ection V(g) of Regulation ---(311a1 facts and arguments not appearing in his application osbt 3062 10/2/34 -16"alld accomm the, _anying forms were submitted for the consideration of Board. ."Baaed upon the additional facts and arguments presented th' 4. 1:1 accordance with your recommendation, the Board has approved 0 apPlieation of Lr. Riley and there are inclosed the original e4d 0Pies of a ulayton Act permit covering his service as director mia °fficer of The First National Bank of Plattsburg, Plattsburg, e°1111) and as director and officer of the Bank of Osborn, Osborn, Ealds°,141) for transmittal by ,you to La.. 1-tiley and the two banks, yo„: COPY for your files. The Board suggests that when you submit tii-L reco mmendation as a result of your annual review of this perYOU report fully as to whether there have been any further betktelsras of the operating practices and credit policies of the lor which Ls.. Riley may be responsible." Approved. Letter dated October 1, 1934, approved by three members of the ()11rtl) t *lalsh) federal Reserve Agent at the /federal Reserve or : 41 Bank "lat he 39 illeloaing the following Clayton Act permit and requesting advise the applicant of the Board's position in the matter of 4ttelacialIce at d irectors, meetings, and that, when the agent submits 414 l'ecoraraeZdation as a result of his annual review of the permit, he 413011 tlaiy, as to the applicant's attendance at directors' meetings 44c1 48 to the to mariner in which he has discharged his duties as a direc- Of u First 14% 17. National Bank of Post City: , (donnell, for permission to serve at the se time ctor and officer of Ihe First National Bank th rth Texas, and as a director of The First ---4L.m of Post City, Post City, Texas. Approved. ' letter8 dated October 1, 1934, approved by four members ar the 4). to ra, tota, 4,q1.3.4e Walsh, Federal Reserve Agent at the Federal Reserve Bank inel1 the following Clayton Act permits, suggesting in Et86 that the agent advise the applicant that it is with the 3063 10/2/34 -17eqeetation that he will satisfactorily attend directors' meetings that Perzit has been granted, and requesting that, when the agent submits recorunendation as a result of his annual review of the permit, he r6Port f ullY as to the applicant's attendance at directors' meetings: 14r. as:r S. Blankinship, for permission to serve at the same time viy; i-rector and officer of The First National Bank of JacksonJacksonville, Texas, and as a director of the First State Overton, Texas. Ihr. G. p kArange, for permission to serve at the same time as 4 dir %ad "tor and officer of The First State Bank, Riesel, Texas, rartas a director of The Farmers and Lerchants National Bank of ' Mart, Texas. Approved. Letters dated October 1, 1934, approved by four members of the aPplicants for permits under the Clayton Act, advising of 41 Of th -eir applications as follows: 14% ;; ( tT A. Curtis, for permission to serve at the same time as °f The Long Island National Bank of Hicksville, Hicksilieks.v.•`"ew York, and as a director of the Bank of Hicksville, ale, New York. wil a dir .liam Duffy, for ville permission to serve at the same time as „ctor ouliu officer of The Long Island National Bank of Hicks'"eksville, New York, and as a director of the Bank of ville, Hicksville, New York. 1,Ir. s tUle:!,.1/81 S. Underhill, Jr., for permission to serve at the same ekair7 a d irector of The Long Island National Bank of Hicksville, New Z /Ic: c and as a director of the Bank of Hicksville, New Mx% clar a di,,!IIT3 T. Bryan, for permission to serve at the same time A114,04 -.'„,c or and officer of the First National Bank at Albion, llatio4111448Ylvania, and as a director and officer of The Girard Bank, Girard, Pennsylvania. x direet s !?!;1frY, for permission to serve at the same time as a anL, officer of The Guarantee State Bank, rangum, Oklahoma, 3064 -18as a director and officer of The First National Bank of -"41erst) Amherst, Texas. 141". Walter Canter, for permission to serve at the same time as 0Yee of The ell1Pl First National Bank of St. Joseph, St. Joseph, ,4•Lsa TA -4-1, `4 and as an employee of the First Trust Company, St. -w8ePh, tlissouri. Mr. for permission to serve at the sane time as of j0 IL°Ificer of The First National Bank of St. Joseph, St. Joseph, xo a°1111-3 and as an employee of the First Trust Company, St. seph, Missouri. Mr. "Rbrey, for permission to serve at the same time as 4(14 4-rector of The First National Bank of Denver, Denver, Coloeqz°2 alld as a director and officer of The International Trust PanY, Denver, Colorado. 1! Approved. 14 atockThere was then presented the following application for a change °4 a Federal reserve bank: 11 1311striet 1,-;.4901* ORIGINAL Stock: IYIZst National Bank at Manistique, 44i8t1qUs, Michigan Shares 36 36 Approved. Thereupon the meeting adjourned. Assistant Secretary. Vice Governor.