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A meeting of the Federal Reserve Board was held in
Washington on Tuesday, October 31, 1933, at 11:25 a. m.
PRESENT:

Mr.
Mr.
Mr.
Mr.
Mr.
Mr.

Black, Governor
Hamlin
Miller
James
Thomas
Szymczak

Mr. Morrill, Secretary
Mr. Martin, Assistant to the Governor
Wyatt, General Counsel
Governor Black submitted the following statement for inclusion in the Board's minutes:
"On Sunday, October 29, 1933, I was invited to a conference
at the White House. At this conference there were present:
The President
Mr. Bruere
Mr. Kent
Mr. Crane
Governor Harrison
Mr. Warren
Mr. Rogers
Mr. Morgenthau
Mr. Jones
Mr. Acheson
Mr. Black
"The President reviewed the present situation especially as
it related to agriculture.
"He then stated that in pursuance of his policy to raise the
level of commodity prices he had determined to have the
Government, operating through the Reconstruction Finance
Corporation, buy gold in the world market. He then asked
for information and opinions as to the best mechanism covering such purchases. After discussion it was determined
that the ileconstruction Finance Corporation should purchase
the gold in the world market and should finance such purchases through its debentures, and, the means being thus
afforded, the most efficacious proceeding would be, first,
to have the Reconstruction Finance Corporation deliver to
the Federal Reserve Bank of New York as its agent its debentures covering the cost of the gold purchased in the




535
10/31/33

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"world market; second, the Federal Reserve Bank of New York,
operating through regular channels, would buy francs or
sterling and convert such francs or sterling into gold for
the account of the Reconstruction Corporation; third, the
gold so purchased would be delivered to the Reconstruction
Finance Corporation at the price paid and such price would
be paid out of the debentures of Reconstruction Finance
Corporation delivered to the Federal Reserve Bank of New
York; fourth, such transactions on the part of the Federal
Reserve Bank of New York would be solely as agent of the
Reconstruction Finance Corporation and at the risk and expense of that Corporation.
"Governor Harrison and I stated to the conference that in
our opinion the mechanism proposed was practicable and that
I would recommend that the Federal Reserve Board grant
necessary permission to the Federal Reserve Bank of New
York and Governor Harrison would recommend it to the directors of the Federal Reserve Bank of New York.
"It was stated at the conference by the President that the
operation would be by the Federal Reserve Bank of New York
and transactions would be had by it in line with the proposed policy of the Government, reports to be made of its
operations and the results of those operations, and that
if the dollar was unduly depreciated the operation night
be reversed.
"It was further agreed at the conference that Governor
Harrison might immediately acquaint the Bank of England
and the Bank of France with the present objective of the
Government in these transactions.
"On Monday morning, October 30, 1933, I informally acquainted
the members of this Board of the scope and details of this
conference, and was informally advised by the Board members
that when formally presented they would permit the Federal
Reserve Bank of New York to engage in the necessary operations subject only to legal restrictions.
"I then requested the opinion of our Counsel, Mr. Wyatt, as
to the right of a reserve bank to purchase debentures issued
by the Reconstruction Finance Corporation. Later in the
day on Monday I received the opinion of Mr. Wyatt in which
opinion he stated that under the law a Federal Reserve Bank
could not purchase debentures of the Reconstruction Finance
Corporation. This opinion was considered informally by the
Board members and it was thought that since this program
was originated by the President it would be proper and
courteous to have an opinion on this legal question from
the Attorney General. The President agreed to the propriety



5R6
- 3 -

10/31/33

"of this request and stated that he would request such
opinion.
"The Board will understand, and the President was so informed, that this program can be carried out in connection with a member bank or banks without the purchase
of such debentures by the Federal Reserve Bank of New
York, but, if legal, it would seem proper to have the
transaction fully handled by the Reserve Bank."
At the request of Governor Black the Secretary read to the
Board a telegram addressed to the Board under date of October 30, signed
by Mr. Crane, Deputy Governor of the Federal Reserve Bank of New York,
which was received this morning, and which reads as follows:
"At the meeting of the executive committee of our board of
directors today the following resolution was adopted:
Voted that, subject to the approval of the Federal Reserve
Board, this bank may, in accordance with the request already received from the Reconstruction Finance Corporation,
act as fiscal agent of that Corporation in the sale of its
debentures or notes in the form to be prescribed by the
Reconstruction Finance Corporation, and at rates of interest or discount to be fixed by it, against payment in gold
recovered fram natural deposits in the United States or any
place subject to the jurisdiction thereof, and may also, if
so requested by the Reconstruction Finance Corporation, act
as fiscal agent of that Corporation in the sale of such debentures or notes against payment in gold acquired abroad,
the price at which such gold is to be accepted in payment
for such debentures to be fixed by the Reconstruction Finance Corporation, and that the officers of this bank be,
and they hereby are, authorized to do and perform such acts
and to sign and execute such agreements as they may deem
necessary or advisable in order to carry out the purposes
of this resolution.
"We shall appreciate advice of the Board's action on this
matter."
Thereupon the members of the Board entered into a discussion
"to whether the resolution quoted in Mr. Crane's telegram covered all




-4

10/31/33

the authority intended to be exercised by the Federal Reserve Bank of New
York in view of Governor Black's statement, and indicated a desire to have
for the purposes of the record a copy of the request received from the
Reconstruction Finance Corporation to which reference was made in the telegram.
Governor Black then left the room for the purpose of talking
over the long-distance telephone with Mr. Crane and upon his return said
that while he was talking to Mr. Crane Governor Harrison had cone in;
that Governor Harrison had been endeavoring to work out an agreement with
the Reconstruction Finance Corporation; and that Governor Harrison had
said that for the present the resolution as quoted in Mr. Crane's telegram
contained all the authority that the Federal Reserve Bank of New York
desired.
At the suggestion of Governor Black, Governor Harrison was
invited to

COMB

into the meeting.

Governor Harrison said that the method

Of handling the matter had been worked out with the Reconstruction Finance
Corporation and
that yesterday the President had expressed the thought that
the method proposed was the best way.

At the suggestion of one of the mem-

bers of the Board, Governor Black read to Governor Harrison the memorandum
which has been quoted in these minutes.

Governor Harrison said that during

the meeting on Sunday the President asked him for his views as to the
mechanics by which the proposed objectives could be attained, but expressly
stated that he was not seeking an expression of opinion as to the policy or
wisdom of the proposed action; that he answered that the most obvious and
Clearly legal course was to handle the matter through a member bank if such




538
10/31/33

- 5 -

nember bank were willing to do so; and that mechanically it could be done
through the Federal Reserve Bank, but that there were two questions upon
which he was not prepared to express an opinion, one being whether the Federal Reserve Bank had a legal right to buy debentures issued by the Reconstruction Finance Corporation, with respect to which Governor Harrison said
that he was very doubtful, and, second, whether it was wise as a matter of
13°11.eY for the Federal Reserve Bank to do so, as to which he could not undertake to express an opinion without consultation with his associates and the
board of directors of the Federal Reserve Bank of New York; but that he preferred an arrangement with a member bank.

Governor Harrison added that, ac-

cording to his understanding, it was left that he should explore the question
Of Policy involved and that Governor Black should explore the question of law.
Governor Harrison said that later Governor Black advised him informally of
lixe, Wyatt's opinion, which he thought he agreed with, although he had not
"tidied it carefully.

He then said that the President had sent for him

Yesterday afternoon and asked him about the mechanics of the proposed action,
that he
told the President that he felt that it would be better to handle it
through a member bank and asked whether the President would have any objection to
doing it through a single member bank in New York; and that the
1°Ileeident replied that he had no objection if the right were reserved to
ebarle the procedure
if it becarle desirable to do so later.

Governor

lirrison said the President inquired about the possibility of the Federal
Ileserve Bank handling the operation and that in reply he referred to the
8111.3 two questions that he had mentioned on Sunday, whereupon the President
'
e 1(1, that he
need not consider these questions any longer but could arrange




539
10/31/33

- 6

to conduct the operation through the member bank without the purchase of
the debentures by the Federal Reserve Bank, that the Attorney General was
away and would not be back for three days, and that he did not feel it
necessary to devote further time to the two questions which Governor
Harrison had raised.

Governor Harrison said that when he left the

President it was clearly understood that what was approved was the conduct of the operation through a member bank in New York, and that he immediately informed Mr. Crane over the telephone and through him the directors of the New York Ban, who were then in session, feelinc; that
there was no point in their considering further the question of policy
as to the Federal reserve bank unless it should develop that the President
wanted to go further.
Governor Harrison informed the Board that he had been working
with Mr. Tones on a draft of a letter to be addressed by the Reconstruction
Finance Corporation to the Federal Reserve Bank of New York covering the
Procedure which was to be followed, and that before the letter was transmitted to the Federal Reserve Bank of New York it would be submitted to
the President.

Governor Harrison added that the resolution as quoted in

the telegram from
Mr. Crane contained all the authority which it was desired that the Board approve for the Federal Reserve Bank of New York at
this time.

Be said also that he had told Mr. Jones that the Federal Re-

serve Bank of New York would
not want to act as fiscal agent for the
le oonstruction Finance Corporation in selling its debentures unless it
had an opinion of counsel for the Reconstruction Finance Corporation
that the issuance of these debentures was legal and that he pointed out




,51
- 7-

10/31/33

to Mr. Jones that any banking institution which undertook to perform such
a service would make a similar request.

In the course of further discussion

Of the operation Governor Black stated that the President had said that the
handling of the matter in furtherance of the end desired was to be entirely
in the judgment of the Federal Reserve Bank of New York. 11r. Hamlin then
said to Governor Harrison that the telegram presupposes that the operation
will be carried on entirely through a member bank and Governor Harrison
answered that Mr. Hamlin's understanding was correct.

At this point Governor

Harrison left the meeting.
Thereupon the Board voted to authorize the Federal Reserve Bank of New York to act as fiscal agent of the Reconstruction Finance Corporation, in accordance with the resolution quoted in the wire of October 30 from Deputy Governor
Crane of the Federal Reserve Bank of New York, addressed to
the Federal Reserve Board, and the Board's Secretary was requeste to wire Mr. Crane accordingly.
The Secretary then brought to the attention of the Board a telegram dated October 26 from Acting Governor Johns of the Federal Reserve Bank

or

Atlanta as follows:
"Jones, Chairman, Reconstruction Finance Coruoration, has requested this bank to act as Fiscal Agent under provisions of
Section 7 of the Reconstruction Finance Corporation Act in the
matter of distribution of its notes payable in newly mined gold.
Section 7 of the Act authorizes and directs Federal reserve banks
to act as Fiscal Agent for the Corporation but before replying
would like to know that the Federal Reserve Board approves our
complying with the Reconstruction Finance Corporation's request."
Thereupon the Board voted to interpose no objection
to the Federal Reserve Bank of Atlanta acting as fiscal agent
for the Reconstruction Finance Corporation with respect to
the distribution of debentures of the Reconstruction Finance
Corporation in accordance with the request contained in the
wire from Mr. johns, and the Secretary was requested to advise 7:r. Johns accordingly.




-8 -

10/31/33

Governor Black stated that all of the appointive members of the
Board and the Comptroller of the Currency had indicated their approval
of the draft of reply to the letter dated September 22, 1933, from Mr.
Herbert Fels, Economic Adviser of the State Department, to which reference was made at the meeting of the Board on October 25, 1932, and that,
accordingly, the reply, which reads as follows, was forwarded to Mr. Feis
on October 31, 1933:
"Reference is made to your letter of September 22, 1933 (-7,A
462.00 R 296 B.I.S./339) transmitting a copy of a letter
from the Secretary General of the Monetary and Economic
Conference requesting advice as to whether the United States
Government would be prepared to grant to the Bank for International Settlements privileges similar to those contained
in Article 10 of The Hague Agreement of January 20, 1930.
Article 10 of the Agreement reads as follows:
'The Bank (for International Settlements), its
property and assets, and also the deposits of other
funds entrusted to it, on the territory of, or dependent on the administration of, the Parties shall
be immune from anrdisabilities and from any restrictive measures such as censorship, requisition,
seizure or confiscation, in time of peace or war,
reprisals, prohibition or restriction of export of
gold or currency and other similar interferences,
restrictions or prohibitions.'
"In the draft of uniform text transmitted for the consideration
Of those governments which may be interested in granting such
immunities to the Bank for International Settlements, which
was also inclosed in your letter, it is noted that it is contemplated that a government agreeing to grant such immunities
would also agree that any disi:ute between such government and
the Bank for International Settlements as to the interpretation
or application of the grant of immunities should be referred
to the Arbitral Tribunal provided for by the said Agreement of
January 20, 1930.
"All of the possible implications of the provisions of Article
10 of The Hague Agreement above quoted are not clear. In considering the matter, however, the Board has noted that Article
10 provides that the Bank for International Settlements shall




10/31/33

- 9 -

"be immune from prohibitions or restrictions on the export of
gold or currency. As you know; the Executive Order of the
President of August 28, 1933, which was issued pursuant to the
provisions of the Act of October 6, 1917, as amended by the
Act of March 9, 1933, prohibits the earmark or export of gold
coin, gold bullion, or gold certificates from the United States
except under license therefor issued by the Secretary of the
Treasury. The Secretary of the Treasury is authorized in his
discretion to issue licenses permitting the export of gold in
certain prescribed cases including: 'The export of gold coin
or gold bullion earmarked or held in trust since before April
20, 1933, for a recognized foreign government, foreign central
bank, or the Bank for International Settlements'. Inasmuch
as the President has in this Executive Order restricted the
export of gold, it would seem that no special exception other
than that which has been provided in the Order with respect to
gold earmarked or held in trust should be made in favor of the
Bank for International Settlements or any other foreign bank.
In the circumstances, the Board feels that it would not be desirable for the United States to become a party to the proposed
agreement in favor of the Bank for International Settlements."
Approved.
The Secretary reported that the Comptroller of the Currency toasY issued a call on all national banks for reports of condition as at the
close of business on October 25, 1933, and that, in accordance with the
usual practice, a call was made on behalf of the Federal Reserve Board on
ell State member banks for reports of condition as of the same date.
The call made on behalf of the Board
was ratified.
The Board then considered and acted upon the following matters:
Reply to a letter dated October 16, 1933 from Governor Geery
"the Federal Reserve Bank of Minneapolis stating that the bank's paying
teller, Mr. V. A. Nelson, an ex-service rAn, applied to the Veterans
Adlanistration for hospital treatment and was notified to appear on March
10 last for examination and operation if necessary; that March 10 was in




10/31/33

- 10 -

the middle of the bank holiday when the bank's tellers were working day
and night and that, thinking it would be unfair to other tellers for him
to leave at that time, he arranged for a postponement of a week; that on
March 17 the tellers were still working until midnight or later and that
Governor Geery, at Mr. Nelson's request, wrote the doctor explaining the
circumstances and asking for a further postponement; and that on March 22
1.

Nelson was notified that all examinations had been discontinued on in-

structions from Washington.

Governor Geery's letter stated also that on

APril 8, 1933, Mr. Nelson was taken ill and an operation was performed three
days later at a cost
of

235.95, which expense he could have avoided had he

taken advantage of the privilege granted him by the Veterans Administration;
that the executive committee of the Federal reserve bank had voted to reimburse Mr. Nelson for this expense; that the board of directors of the bank,
at its last
meeting, had confirmed this action; and that the Board's approval
of the action is
requested.

The reply stated that, in view of the circum-

stances connected with the case, and particularly in view of the fact that
Governor Geary felt the work of the bank was such as to justify his writing
tO the
employee's doctor asking for a Postponement of his examination, the
Board interposes
no objection to the Federal reserve bank reimbursing Mr.
Nelson for the
expense incurred by him in connection with the operation,
with the
understanding that the approval should not be construed as a precedent for any similar cases which may arise in the future.
Approved.
Letter to Mr. McClure, Federal Reserve Agent at Kansas City,
etat
ing that the Board approves the bond in the amount of .4;50,000 executed




10/31/33

- 11 -

under date of September 27, 1933, by Mr. N. R. Oberwortmann as Assistant
Federal Reserve Agent at.the Federal Reserve Bank of Kansas City.
Approved.
Letter dated October 30, 1933, to the board of directors of "The
Citizens Bank of Mount Blanchard", Mount Blanchard, Ohio, approved by five
members of the Board, stating that, subject to the conditions prescribed in
the letter, the Board approves the bank's application for membership
in the
Federal reserve system and for the number of shares of stock of the Federal
Reserve Bank of Cleveland to which the bank will be entitled upon the basis
01' its capital
and surplus as of the date upon which its membership becomes
effective.
Approved.
Telegram to Mr. Walsh, Federal Reserve Agent at Dallas, relative
to the
proposed name of a company to be organized to take over the real estate and insurance
business of the Southern Arizona Bank and Trust Company,
Tucson,

Arizona, which, under the conditions of membership imposed by the

Board in connection with the company's application for membership in the
Federal reserve system, was required to dispose of such business prior
to
4amission to
membership.

The telegram stated that the Board interposes no

ob jection to
the name "Arizona Realty and Trust Company" for the new co:':.pany,
but

suggests that the words "and Trust" be eliminated from the name of the

proposed company.

It

Approved.
Letter dated October 30, 1933, to "The First National Bank of
asefferson

Parish at Gretna", Gretna, Louisiana, approved by five members




10/31/33

- 12 -

545

of the Board, referring to the application filed in the bank's behalf for
permission to exercise fiduciary powers under the provisions of section
11(k) of the Federal Reserve Act, and stating that the Board has considered
the application and authorizes the bank to act, when not in contravention of
State or local law, as trustee, executor, aaministrator, registrar of stocks
and bonds, guardian
of estates, assignee, receiver, committee of estates of
lunatics, or in any other fiduciary capacity in which State banks, trust companies or other corporations which come into competition with national banks
are permitted to act under the laws of the State of Louisiana, only in the
specific trusts in which the Gretna Trust and Savings Bank, Gretna, Louisiana,
had been appointed and was acting on the date The First National Bank of
Xefferson Parish at Gretna, Louisiana, was authorized to commence business
bY the Comptroller
of the Currency, the exercise of all such rights to be
subject to the provisions of the Federal Reserve Act and the regulations of
the Federal
Reserve Board.

The reply stated also that action has been de-

ferred upon the bank's application for full fiduciary powers until the institution has been in operation for at least one year and a report of an examination made subsequent to the expiration of that period has been received.
Approved.
Letter dated Octobe: 30, 1933, to "The First National Bank of Bay
Cit
"
, Bay City, Texas, approved by five members of the Board, stating that
the Board
approves the bank's application for permission to act, when not in
colltravention of State or local law, as trustee and registrar of stocks and
b°11c189 the exercise of such rights being subject to the provisions of the
Federal Reserve Act and
the regulations of the Federal Reserve Board.




Approved.

546
10/31/33

- 13 -

Telegram to the Federal reserve agents at all Federal reserve
banks stating that the prohibitions of section 8A of the Clayton Antitrust
Act, as amended, apply to directors of Federal reserve banks and their
branches, and that it is assumed that consideration is being given to this
Point in connection with the forthcoming elections of ClassA and B directors of each Federal reserve bank, and that the board of directors of each
bank will give the matter consideration in making appointments of directors
of branches, if any, for terms beginning Ianuary 1, 1934.

The telegram also

requested that each Federal reserve agent investigate and advise the Board
immediately whether the Class C director of his bank and directors of branches,
if any, whose terms expire December 31, 1933, have any affiliations coming
within the prohibitions of section 8A of the Clayton Act; that he furnish
the Board with
full information with regard to such affiliations and particularly whether they are with non-banking institutions; and that, in the event
the Board's
district committee has taken up with the Federal reserve agent
the matter of
the selection of a successor to any branch bank director
Whose term expires
on December 31, 1933, information need not be obtained
covering the present incumbent, but Should be furnished covering the proPosed successor.

The telegram stated further that a survey should be made

also of other
directors of each Federal reserve bank and branches, if any,
to
determine whether it will be necessary for them to obtain permits, or,
7thether they have
affiliations with non-banking institutions coming within

the Prohibition of section
8A, which will make them ineligible to serve
at the
same time as a director of a Federal reserve bank or branch.




Approved.

547
10/31/33

Telegram to Mr. Case, Federal Reserve Agent at New York, requesting that he advise Mr. Brandwen, New York, New York, counsel for the Amalgamated Bank of New York, New York, as follows:
"Referring to question whether Amalgamated Clothing Workers of
America is holding company affiliate of Amalgnmated Bank of New
York, Board understands that two individuals as trustees hold
less than a majority of stock of member bank, but more than
fifty per centum of number of shares voted for election of directors of such bank at preceding election. From information
furnished it appears that Amalgamated controls such stock indirectly through medium of trustees, and accordingly, that
Amalgamated is affiliated with such member bank in manner described in Section 2, subsection (c) of Banking Act of 1933 and
that it is holding company affiliate of such bank within meaning of Act. Board extends until and including November 7, 1933,
time within which Amalgamated Bank of New York must obtain and
file agreement by its holding company affiliate on Federal Reserve Board Form P-5. Board has taken similar position in regard to question whether Chicago Joint Board is holding company
affiliate of Amalgnmnted Trust and Savings Bank, Chicago, Illinois, and has so advised Federal Reserve Agent at Chicago by
telegram of this date."
Approved.
Telegram to Mr. Stevens, Federal Reserve Agent at Chicago,
reading
as follows:
"BY telegram September 25, Board advised you it would appear
that Chicago Joint Board, Amnlgamated Clothing Workers of
America, is holding company affiliate of Amalgamated Trust
and Savings Bank,
Chicago, Illinois, if it is affiliated with
such bank in any manner described
in Section 2, subsection
(c) of '3!Inking Act of 1933. At request of counsel representing bank, Board has given further consideration to this matter. From information furnished,
Board understands that
three individuals, as trustees,
hold approximately 75 per
centum of stock of bank, and it appears that Joint Board controls such stock indirectly
through mediu:q of such trustees.
Accordingly, it would appear that Joint Board is affiliated
with member bank
in manner described in Section 2, subsection
(c) of Act, and that
it is holding company affiliate of such
bank within meaning of
Act. Board extends until and including
November 7, 1933, time within which Amalgamated Trust and
Savings Bank must obtain and file agreement by its holding
company affiliate on F. R. B. Form
P-5."




Approved.

548
10/31/33

- 15 -

Reply on October 30, 1933, approved by five members of the Board,
to a letter dated October 10 from Er. Carl R. Korb, Vice President of the
Union Trust Company of Pittsburgh, Pennsylvania, referring to his letter of
September 22 in which he stated that the trust company has received from the
Federal Reserve Bank of Cleveland F.H.B. Forms P-1 to P-6, inclusive, to be
used in an application by a holding company affiliate for a voting permit
under section 5144 of the Revised Statutes as amended.

The reply stated

that in acting upon an application for a voting permit the Board is required under section 5144 to determine whether the granting of the permit
would be in the public interest, that Regulation P and the accompanying
fcrms were prepared with a view to obtaining the information necessary for
a Proper
consideration of this question; that, therefore, in answer to Er.
Xorbts first question, it is necessary for each applicant to furnish as
Part of its
application all information which in the particular case is
called for by paragraph 13 of Form P-1; and that the necessity is not
eliminated by the fact that the applicant or the subsidiary or both are
Members

of the Federal reserve system, but that if any information required

by F.R.B. Form P-1 has been furnished to the Federal reserve agent and to
the Board prior
to the filing of the application, the applicant may incorPorate such
information in the application by reference.

In response to Er.

IC°113's inquiry as to whether it is essential that all the various forms and
IleDorts be filed
in triplicate, the reply stated that the Board realizes that
the necessity of preparing copies of voluminous papers may be burdensome,
hilt that the
requirement of submission in triplicate was decided upon after
ca'I'eful consideration
of the procedure to be used in passing upon the numerous




10/31/33

aPplications to be submitted and that no exception appears here to be
justified.
Approved.
Reply on October 30, 1933, approved by five members of the Board,
to a letter dated
September 13 from Wise, Shepard & Houghton, New York, New
York; the reply reading as follows:
"Your letter of September 13, 1933, addressed to the Comptroller
Of the Currency has been referred to the Federal Reserve Board.
"You ask, first, whether section 32 of the Banking Act of 1933 is
applicable to certain directors of the Continental Bank and
Trust Company of New York who are members of the New York Stock
Exchange. That section is applicable to the service of an
Officer or director of a member bank as 'an officer, director,
or manager of any corporation, partnership, or unincorporated
association' engaged primarily in buying, selling, or negotiating
securities. Since the statute refers only to an 'officer, director or manager' of the organizations of the kind referred to, the
mere fact that the directors to whom you refer are members of
the New York Stock Exchange would not make that section applicable
to them.
"You also ask whether that section is applicable to directors of
that bank who are partners in firms which do a New York stock
exchange business. It appears that the word 'manager' in the
provision quoted above includes any person who manages, controls,
or directs the business of an organization engaged primarily in
Purchasing, selling or negotiating securities, or who participates in such management or control, either at the main office
or at a branch office, branch, etc., of such organization, and
therefore includes arygeneral partner in a partnership princiPally engaged in such business; and this conclusion is strengthened
by the reference to 'partnership' in the words immediately following the words 'officer, director or manager'. However, it also
appears that the provision in question is inapplicable to an inactive partner in such a Pa-tnership who has no voice in the
management or control of its business and whose liability is
limited to the amount of his contribution to the partnership.
"You also ask whether that section is applicable to directors of
th'2,t bank who are employed by or associated with a New York stock
exchange firm. Section 32 does not contain a reference to 'emPloyees', and unless the persons to whom you refer may properly




10/31/33

550

- 17 -

"be classed as 'directors', 'officers', or 'managers' of the
New York stock exchange firms, the provisions of section 32
would not be applicable to them."
Approved.
Reports of Standing Committee dated October 31, 1933, recamraending approval of the following changes in stock at Federal reserve
banks:
Aaliaation for ORIGINAL Stock:
District No. 2.
National Ulster County Bank, Kingston, N.Y.
A2p1ication for SURRENDER of Stock:
District No. 11.
National Bank of Commerce, Amarillo, Texas
(Insolvent)

Shares
180

180

90

90

Approved.
Thereupon the meeting adjourned.

413Proved:




Governor,