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Minutes for September 1, 1964

To:

Members of the Board

From:

Office of the Secretary

Attached is a copy of the minutes of the
Board of Governors of the Federal Reserve System on
the above date.
It is not proposed to include a statement
with respect to any of the entries in this set of
minutes in the record of policy actions required to
be maintained pursuant to section 10 of the Federal
Reserve Act.
Should you have any question with regard to
the minutes, it will be appreciated if you will advise
the Secretary's Office. Otherwise, please initial
below. If you were present at the meeting, your
initials will indicate approval of the minutes. If
you were not present, your initials will indicate
only that you have seen the minutes.

Chm. Martin
Gov. Mills
Gov. Robertson
Gov. Balderston
Gov. Shepardson
Gov. Mitchell
Gov. Daane

295
Minutes of the Board of Governors of the Federal Reserve
System on Tuesday, September 1, 1964.

The Board met in the Board

Room at 10:00 a.m.
PRESENT:

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

Martin, Chairman
Balderston, Vice Chairman
Mills
Robertson
Shepardson 1/
Mitchell
Daane
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.
Mr.

Kenyon, Assistant Secretary
Molony, Assistant to the Board
Fauver, Assistant to the Board
Hackley, General Counsel
Brill, Director, Division of Research
and Statistics
Solomon, Director, Division of
Examinations
Conkling, Assistant Director, Division
of Bank Operations
Kiley, Assistant Director, Division of
Bank Operations
Goodman, Assistant Director, Division of
Examinations
Leavitt, Assistant Director, Division of
Examinations
Smith, Assistant Director, Division of
Examinations
Sprecher, Assistant Director, Division
of Personnel Administration
Langham, Assistant Director, Division
of Data Processing
Spencer, General Assistant, Office of
the Secretary
Forrestal, Attorney, Legal Division
McClintock, Supervisory Review Examiner,
Division of Examinations
Veenstra, Chief, Financial Statistics
Section, Division of Data Processing

1/ Entered meeting at point indicated in minutes.

Aw#

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Discount rates.

The establishment without change by the Federal

Reserve Banks of Atlanta and Minneapolis on August 28, 1964, and by the
Federal Reserve Bank of Boston on August 31, 1964, of the rates on discounts and advances in their existing schedules was approved unanimously,
with the understanding that appropriate advice would be sent to those
Banks.
Branch application (Item No. 1).

Unanimous approval was given

to a letter to First National City Bank, New York, New York, granting
permission to establish a branch in Port-of-Spain, Trinidad and Tobago.
A copy of the letter is attached as Item No. 1.
Mr. Forrestal then withdrew from the meeting.
Report on competitive factors (Albany-Oneonta, New York).

There

had been distributed a draft of report to the Comptroller of the i7urrency
on the competitive factors involved in the proposed merger of The Citizens
National Bank and Trust Company of Oneonta, Oneonta, New York, into
National Commercial Bank and Trust Company, Albany, New York.
Agreement having been expressed with a change in the wording of
the conclusion suggested by Governor Mitchell, the report was approved
unanimously for transmittal to the Comptroller with the conclusion
reaiing as follows:
The proposed merger of National Commercial Bank and
Trust Company, Albany, New York, and The Citizens National
Bank and Trust Company, Oneonta, New York, would eliminate
the competition existing between the two banks, further
strengthen the dominant position of National Commercial Bank
and Trust Company in Otsego County, and place the smaller
remaining bank in Oneonta at a disadvantage. The effect on
competition would be clearly adverse.

9/1/64

-3Mr. McClintock then withdrew from the meeting.
Collection of bank condition data (Items 2 and 3).

There had

been distributed under date of August 27, 1964, a draft of letter to
Chairman Barr of the Federal Deposit Insurance Corporation with regard
to the use of a short form report of condition for the 1964 fall call
date.

The draft had been prepared in response to a letter of August 18,

1964, from Chairman Barr in which he indicated that the Corporation
planned to print a form for the fall call that would be identical with
the statement used for the April 15, 1964, call date and requested to
be informed whether the use of the short form would be consistent with
the intentions of the Federal Reserve.

The draft reply stated that

the Federal Reserve would use a call report form identical with that
used in April.

The letter also would state that the Federal Reserve

had no plans to collect a slip-sheet reconciliation statement from
national banks even if the form to be used by the Comptroller of the
Currency for national banks was not compatible with the State forms.
There likewise had been distributed a draft of letter to the
Comptroller of the Currency, which would refer to the letter from
Chairman Barr and enclose a copy of the reply to him.

The proposed

letter would indicate that a decision on tabulating member bank data
from the fall call had been left unsettled and that use of a slip-sheet
to achieve compatible banking data for all member and all insured banks,
while worthwhile for midyear data, probably would not be justified by

29S3
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the statistical value of fall call report data.

The draft also contained

paragraphs requesting advice on plans of the Comptroller for the fGrmat
of the national bank report form, so that a determination might be made
on whether to commit personnel and machine resources to tabulating national and State member bank reports, and commenting that staff efforts
to draft a uniform report form and procedure on which State and Federal
bank supervisory agencies could agree were progressing, with the hope
- hat agreement could become effective in time for the December call date.
There being no question regarding the draft of reply to Chairman
Barr, discussion focused on the draft of letter to the Comptroller.

It

was suggested that the proposed letter, which had been prepared principally
with the thought of placing on record the efforts of the Federal Reserve
to negotiate a compatible condition report form, served mainly to debate
unnecessarily the question of tabulating the fall call.

It was generally

agreed that the letter could be shortened and should focus on the fact
that the tabulation of the fall call did not warrant the use of reconciliation statements or elaborate editing or tabulation procedures,
although the Board would be willing to undertake the tabulation if the
Comptroller were to include certain memorandum items on the national
bank form.
The letter to the Comptroller was then approved unanimously in
a form reflecting the changes agreed upon during the discussion.

A copy

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of the letter, in the form transmitted to the Comptroller, is attached
as Item No. 2.

A copy of the letter to Chairman Barr, as approved, is

attached as Item No.

3.

Messrs. Conkling, Langham, and Veenstra then withdrew from the
meeting.
Examination of New York Reserve Bank (Item No.

4).

There had

been circulated to the Board the report on the examination of the Federal
Reserve Bank of New York made by the Board's examining staff as of May 22,
1964.

The usual accompanying memoranda also had been circulated, and a

summary memorandum from the Division of Examinations dated August

26,

1964, had been distributed.
At the Board's request, Mr. Smith reviewed the information
developed through the examination, his comments being based on the
material that had been circulated to the Board.
In discussion, Governor Mills observed that the examination
report seemed to give a "clean bill of health" to the expenditures made
by the Bank, the report containing a statement to the effect that all
expenditures had been reviewed and none was considered worthy of comment.

He thought a policy had been agreed upon by the Board that if

there was a shadow of doubt as to the appropriateness of an expenditure,
the item would be noted for the Board as a matter of information.

It

seemed to him that it would be unusual if a Reserve Bank of the size
and with the scope of operations of New York could function without some
expenditure that should be reported in this mcnaer.

28 V

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Mr. Smith noted that the Division of Examinations was endeavoring
to compile a representative sampling of types of expenditures at the
various Reserve Banks that might be of a questionable nature.

When an

adequate cross section was developed, a memorandum going into the subject
in some depth was to be submitted to the Board for the purpose of ascertaining the Board's views as to types of expenditures that might be
considered inappropriate.

Insofar as the New York examination was con-

cerned, the Board's examiners had reviewed all expense vouchers and had
followed the practice of relating such expenditures to outstanding letters
from the Board.

In their judgment, there were no expenditures falling

outside the scope of such letters.
Governor Mills then said it was his recollection that some time
ago the Board had requested that a new approach be developed regarding
the reporting of expenditures.

There had been a clear indication, he

thought, that the Board wished to scrutinize Reserve Bank expenditures
more closely.
In further discussion, the Board indicated that it felt the
ht.lf dozen most recent Reserve Bank examinations would afford a sufficient
sampling from which to compile categories of expenditures for discussion
of their appropriateness.

Accordingly, it was understood that the

Division of Examinations would prepare an analysis on such basis.

It

was also understood, in accordance with a suggestion made by Chairman
Martin, that a listing of expenditures of the New York Reserve Bank

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-7-

noted by the examiners during their review of vouchers at the recent
examination would be distributed to the members of the Board/ it being
understood that the examiners had concluded that such expenditures did
not warrant criticism in the report of examination.
As discussion proceeded, Mr. Smith responded to certain questions about verification procedures used during the New York examination.
At the instance of Governor Mitchell, there followed a discussion relating
to the ownership of bank stock by Reserve Bank employees.
In its letter to the Reserve Banks (S-1907) of February 101 19641
the Board had reiterated the general principle that officers and employees
of a Federal Reserve Bank should refrain from placing themselves in any
position that might embarrass the Bank or the Federal Reserve System as
a whole in the conduct of its operations or result in any questions
being raised as to the independence of an individual's judgment or his
ability to perform satisfactorily all of the duties of his position
with the System.

That letter had referred specifically to the owner-

ship of bank stocks and had expressed the view that it would be inappropriate for a member of the staff of a Reserve Bank to purchase stock
of a bank or an affiliate thereof, except possibly where the actual
relationship of the affiliate to the bank was remote.

The letter further

stated that officers and employees occupying responsible positions and
holding or acquiring stock of banks or affiliates should dispose of it
as promptly as practicable without causing undue hardship.

291...42
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Question was raised specifically at this meeting about bank
stock awned by Mr. Philip Vachon, a supervisory employee in the Foreign
Department who had been acquiring such stock over a long period of time,
reportedly to supplement his retirement benefits.

Through established

reporting procedures, he had periodically informed the Bank regarding
details of his holdings.

The Reserve Bank had reviewed the situation

in light of the recent Board letter and concluded that to require
Mr. Vachon to dispose of his holdings now would be in the nature of
"undue hardship."
The incident was discussed at some length against the background
of the recent Board letter, which according to Mr. Smith had led to a
general review by the Reserve Banks--including New York--of outstanding
cases of bank stock ownership and was undoubtedly resulting in the
issuance of firmer instructions by the Reserve Banks pertaining to the
acquisition of such stock.

The New York Bank was understood to have

made a rather intensive review following receipt of the Board's letter,
but in the case of Mr. Vachon the Bank decided that a requirement for
disposition would involve undue hardship.

In the discussion, certain

extenuating circumstances were recognized by the Board, including the
nature of Mr. Vachon's duties with the Bank and the fact that he had
reported his holdings periodically, without Objection on the part of
Bank management.

Nevertheless, there was some feeling within the Board

that such a situation presented certain aspects of vulnerability, at

9/1/64

-9-

least from a public relations standpoint.

At the conclusion of the

discussion, Chairman Martin noted that the record of this meeting
should contain a notation that this point had been raised; also, the
New York Bank should be informed by letter of the Board's continued
concern about possible conflicts of interest, with reference made to
the responsibility of the Reserve Banks for taking all reasonable measures to assure that persons in their employ avoid any relationships
that might give rise to questions of such character.
agreement with the comments of the Chairman.

There was general

A copy of the letter

subsequently sent to the Federal Reserve Bank of New York is attached
as Item No. 4.
It was agreed that there were no other matters disclosed by
the examination that called for action on the part of the Board at
this time.
Mr. Sprecher then withdrew from the meeting.
Office held by proposed Class C director.

There had been dis-

tributed a memorandum dated August 28, 1964, from the Legal Division in
connection with the question whether the service of a proposed Class C
director of the Federal Reserve Bank of Boston) Mr. James McCormack, as
Chairman of the Board of Directors of the Massachusetts Bay Transportation
Authority would be contrary to the Board's resolution of December 23, 1915,
prohibiting the holding of political or public office by Reserve Bank
directors and officers.

29134
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Pursuant to the understanding at the Board meeting on August 19,
1964, a telegram had been sent to Chairman Canham of the Federal Reserve
Bank of Boston stating that Mr. McCormack had been appointed as a Class
C director for the unexpired portion of the term ending December 31,
1965, to succeed Mr. John T. Fey.

The usual type of telegram tendering

the appointment had been sent to Mr. McCormack under date of August 20,
1964.

In discussion with President Ellis of the Boston Reserve Bank

prior to accepting the appointment, Mr. McCormack had raised a question
concerning his eligibility for the Class C directorship in view of the
fact that he had recently accepted appointment by the Governor

of

Massachusetts as Chairman of the Board of the Transportation Authority.
The memorandum of August 28 noted that the Massachusetts Bay
Transportation Authority was established in 1964 to enlarge and increase
the activities of an earlier organization known as the Boston Metropolitan
Transit Authority.

The Transportation Authority was managed by a board

of five directors appointed by the Governor.

The Chairman of the Authority,

as designated by the Governor, received an annual salary of $10,000; the
Other directors received $7,500 per annum.

The Authority was authorized

to hold, operate, and manage the mass transportation facilities and
equipment to be acquired; to employ officers and employees and set their
compensation; to enter into contracts and leases with others; to provide
mass transportation services within the area constituting the Authority;
and to issue bonds, notes, and other evidences of indebtedness.

In order

'

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to meet the expenditures necessary to carry out the provisions of the
law, the Authority could issue bonds subject to various conditions and
stipulations.
Following discussion, it was agreed unanimously that Mr. McCormack's
service with the Massachusetts Bay Transportation Authority was of a type
that would not be contrary to the spirit and purpose of the Board's 1915
resolution.

It was understood that the Board's view on this matter would

be communicated to Mr. McCormack through Chairman Canham of the Boston
Reserve Bank.
Messrs. Molony, Brill, Kiley, and Smith then withdrew from the
meeting and Messrs. Shay, Assistant General Counsel, and Furth, Adviser,
Division of International Finance, entered the room.
International Banking Corporation.

At the Board meeting on

July 24, 1964, there was preliminary discussion of a proposed reply to
a letter of June 24, 1964, from Chairman James S. Rockefeller of First
National City Bank, New York, New York, regarding certain questions that
had arisen in connection with the agreement under which International
Banking Corporation, a wholly-owned subsidiary of First National City
Bank, was operating pursuant to section 25 of the Federal Reserve Act.
At the conclusion of the discussion on July 24, the Board deferred action
on the matters at issue and requested that additional information be
furnished as to the facts and reasoning involved.

291:36
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There now had been distributed a memorandum from the Division
of Examinations dated August 21, 1964.
July 24 meeting a letter of August

4,

It noted that subsequent to the

1964, had been received from Vice

President George C. Scott of International Banking Corporation requesting
reconsideration of the conditions in the Board's letter of July 23, 1964,
granting consent to acquire shares of Banque de l'Afrique Occidentale.
The memorandum discussed at some length not only the matter raised in
Mr. Scott's letter but also the proposed revision of the agreement under
which International Banking Corporation was operating and the restrictions
on loan operations of its foreign banking subsidiaries, particularly a
Bahamian trust company.

The following three proposals were suggested

for consideration by the Board:
1.

A revised agreement with International Banking Corporation
in order to conform to Regulation K (Corporations Engaged in
Foreign Banking and Financing under the Federal Reserve Act),
as revised effective September 1, 1963.

2.

An exclusion from restrictions on loans made by First
National City Trust Company (Bahamas) Limited in the
Bahamas in the currency of that country. No objection
would be taken to loans granted in excess of the limits
of section 211.9(b) of Regulation K insofar as they
related to the obligations of any person for money borrowed where such obligations were fully secured by the
hypothecation of funds on deposit in the same currency
in the trust company.

3.

A reply tu International Banking Corporation's letter of
August 4, 1964.

On proposal numbered 1, the memorandum noted that provisions
Of the agreement under which the Corporation was currently operating

9/1/64

-13-

had not been changed since the revised Regulation K was adopted effective September 1, 1963.

Various requests had been received from the

Corporation, and requirements in connection with consents granted had
been considered in the light of similar actions with respect to corporations operating under section 25(a) of the Federal Reserve Act.

In order

that requests relating to certain subsidiaries of International Banking
Corporation might be processed expeditiously and activities permitted
to section 25(a) corporations might be available to International Banking
Corporation, the Board's staff had suggested to the Corporation that
consideration be given to revising the agreement under which it operated
SO as to bring it into conformity with Regulation K to the extent applicable.
The memorandum noted, with respect to the second proposal, that
questions had been raised during the discussion at the Board meeting on
July 24 as to the need for permitting any exception on the size of loans
granted by the Bahamian trust company,since First National City Bank had
a direct branch in Nassau.

This suggested that the reasons for exceptions

that had been made from the usual restrictions in relation to loans in
local currency of The Bank of Monrovia in Liberia, The First National
City Bank of New York (South Africa) Limited in South Africa, and The
Mercantile Bank of Canada, as well as the Mercantile Trust Company in
Canada, did not exist in this instance.

The memorandum pointed out,

however, that there might be reasons why clients would prefer to have

-14-

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accounts with a Bahamian-chartered trust company rather than with a
direct branch of a United States bank.

It was suggested, therefore,

that the Board consider modifying its consent so as to give International
Banking Corporation the same exclusion with respect to loans of the
Bahamian trust company as had been given to International Banking Corporation's subsidiaries in South Africa, Liberia, and Canada.
As to the third proposal, conditions in the Board's letter
granting consent to the proposed purchase and holding of shares in
Banque de l'Afrique Occidentale were enumerated, and the Objections to
certain of those conditions, as stated in the letter from Mr. Scott,
were cited.

In particular, Mr. Scott stated that the following conditions

presented obstacles that were believed to be insurmountable: (1) that
International Banking Corporation would not hold any shares of Banque
de l'Afrique Occidentale if the latter at any time failed to restrict
its activities to those permissible to a corporation in which a corporation organized under section 25(a) could purchase and hold stock, or
If Banque de l'Afrique established any branch or agency or took any
action or undertook any operation in France or elsewhere, in any manner,
which at the time would not be permissible if Banque de l'Afrique were
a corporation organized under section 25(a); (2) that, when required
by the Board of Governors, International Banking Corporation would
cause Banque de l'Afrique to permit examiners selected or auditors
approved by the Board to examine the bank and to furnish the Board such

2999

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reports as it might require from time to time; (3) that any share
acquisitions or dispositions by Banque de l'Afrique be reported under
section 211.8(d) of Regulation K in the same manner as if the bank
were a corporation organized under section 25(a) of the Federal Reserve
Act.
Mr. Scott had suggested that the conditions be modified along
the lines of those prescribed by the Board in granting consent for
International Banking Corporation to acquire 16-2/3 per cem. of the
shares of M. Samuel & Co. Limited, London.

With the exception of a

requirement that there be no direct or indirect office or representative
in the United States, the conditions prescribed with respect to the
shares of M. Samuel & Co. were essentially those contained in the statute
or incorporated in Regulation K, as amended.

The Federal Reserve Bank

Of New York had concluded that the objections mentioned by Mr. Scott
merited consideration.

The New York Reserve Bank felt that unless an

Edge or agreement corporation acquired more than 50 per cent of the
voting stock of a foreign bank, or had effective control over the institution, which in this case would be possible only if the balance of
the capital stock were widely held, conditions such as those fixed in
this case should not be imposed.
In commenting on this subject, the memorandum expressed the
belief, notwithstanding the New York Reserve Bank's views, that the
general position taken in the Board's consent letter of July 23, 1964,

3000
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to purchase shares of Banque de l'Afrique Occidentale was appropriate
where

4o

per cent of the shares of a foreign bank were acquired and

that no substantial modification was warranted.
At the Board's request, Mr. Solomon commented upon the matters
discussed in the memorandum of August 21.

In the course of his remarks,

he reviewed the three proposals suggested for the Board's consideration,
but he focused on the proposed reply to the letter of August

4

from

International Banking Corporation, which stated that the conditions
imposed in the Board's consent made it impossible to conclude arrangements for the proposed acquisition of shares.

International Banking

Corporation's partners were French, and the Corporation had expressed
the view that the French Government would prohibit it from participating
in the organization of Banque de l'Afrique Occidentale if that bank had
to operate under conditions such as were now being imposed by the Board.
Therefore, International Banking Corporation requested that the Board
reconsider the conditions prescribed when the consent was granted and
asked that the restrictions be no more onerous than those imposed when
the Board allowed it to purchase an interest in M. Samuel & Co.
Mr. Solomon went on to say that he had given considerable thought
to the restrictions imposed in the Board's consent and had come to the
conclusion that the Board should reconsider them.

He noted that the

Bank Holding Company Act used 25 per cent ownership of the voting shares
of a bank as a rule for determining "control."

As a practical matter,

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25 per cent ownership might well be considered to constitute control,
If this was not technical control, it did provide

Mr. Solomon agreed.

enough influence to have a profound effect on the operations of an
organization.

In his view, the 25 per cent rule was sound for use in

a domestic situation, where the principal concern was with competitive
ramifications.

However, investments in foreign banks essentially

involved considerations of soundness, not considerations of competition.
Mr. Solomon went on to note that the Federal Reserve Bank of
New York, in reviewing the objections of International Banking Corporation to the conditions contained in the Board's consent, felt strongly
that unless an Edge or agreement corporation acquired more than 50 per
cent of the voting stock of a foreign bank, or had effective control
over the institution, conditions such as those fixed in the Banque de
l'Afrique case should not be imposed.
would be acquiring

4o

International Banking Corporation

per cent of the shares of Banque de l'Afrique,

and no doubt had thoroughly assessed the soundness of the proposition.
It seemed to him, Mr. Solomon indicated, that where an Edge or agreement
corporation was making an investment of 25 to 50 per cent in a foreign
bank, the Board should reconsider its conditions.

The reasoning he

employed might in fact extend to investments beyond 50 per cent, but

he would not pursue that phase of the matter for the moment.
Following Mr. Solomon's remarks, Mr. Furth commented in a somewhat different vein.

The general tenor of his remarks indicated a belief

t

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that there was need for restrictions to be imposed, even agreeing that
competitive considerations in the case of an investment in a foreign
banking institution were not as important as in a domestic situation.
The factor of soundness entered in to an important extent, he felt,
and the Board should maintain a framework of conditions sufficient to
insure the adequate exercising of its responsibilities as a supervisory
agency.

Keynoting Mr. Furth's argument was the view that a logical

case could hardly be made, when considering what conditions should be
imposed, for distinguishing between 25 per cent ownership of shares
and 50 per cent ownership; as a practical matter, anything over 25 per
cent ownership no doubt carried with it an ability on the part of the
investing U. S. corporation to have knowledge of the foreign corporation's
operations and an influence in its policies and affairs.

He did feel,

however, that some distinction could be made between the situation in
the Banque de lt Afrique case and the situation in the M. Samuel case,
Which involved a relatively small participation in a long-established
British firm.
Mr. Solomon replied, in effect, that in his view conditions
such as had been prescribed in the Banque de 11 Afrique case did not
assure the soundness of operations to which Mr. Furth had referred.
As he saw it, such conditions were essentially irritants; they simply
gave the impression of the long arm of the United States Government

being extended into a company the majority of whose stock would be
French owned.
Governor Shepardson entered the meeting at this point.

3
t

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In further discussion, Governor Mitchell commented that where
an American bank was involved in an operation abroad, the public tended
to identify the foreign operation not only with the United States bank
but with the United States Government, and to look for certain standards.
He was of the view that enough control should be exercised to insist on
certain standards of operation.

But here a difficult problem could

arise, because judgments could differ from case to case.
that if International Banking Corporation owned

4o

One might say

per cent of the stock

of a foreign bank, the prestige of the parent institution, First National
City, was involved.

But another case, like M. Samuel, might be regarded

as simply involving a minority investment.
draw the line.

The question was where to

As he looked at the situation, he concluded that a list

should be prepared for the Board's information that would indicate the
types of conditions imposed on ownership in various foreign banking
corporations.

The object would be to determine which types of conditions

seemed to be addressed to assuring the degree of supervision that the
Congress apparently felt, in formulating the statute, should be exercised
over the foreign operations of U. S. banks.
Governor Mills observed that the Board's fundamental responsibility was to see that Edge and agreement corporations were operated in
ways that would not expose shareholders and depositors of the parent
organizations to undesirable risks.

Through examination and inspection

30t.4

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of the Edge and agreement corporations, he thought it should be possible
to obtain an adequate insight into such operations.

It seemed to him

that in the present case, for example, the records and reports available
through First National City Bank and International Banking Corporation
should be sufficient to give the Board adequate information, and that
the Board should be careful about splitting hairs

based on percentage

Of ownership as a criterion for deciding whether it should insist on
reserving the right of access to the books of foreign banks.

For this

reason he was attracted to the position of Mr. Solomon despite his basic
reservations about the eventual results of the activities being pursued
by Edge and agreement corporations around the world.
After Mr. Goodman had commented on the guidelines heretofore
applied in formulating conditions pertaining to various foreign stock
acquisitions, which he felt had been applied with a reasonable degree
of consistency, and on the nature of practices followed in the examination of Edge and agreement corporations, Chairman Martin noted that the
issue before the Board today typified the general questions in this area
that had been debated by the Board, in one form or another, over an
extended period of time.

In his own thinking, he started with an as-

sumption that normally it would be preferable for an American bank, rather
than competing international banking interests, to have the opportunity
to make an investment if this could be worked out in a reasonable way.
In recent years, he felt that American banks had lost out on a number of

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such opportunities because the difficulties of regulation were too
great.
view.

Within the Board, however, this had appeared to be a minority
The difference between 25 per cent and 50 per cent ownership was,

to his mind, a very minor point.

Essentially, the Banque de l'Afrique

venture was, to some extent at least, a speculative operation that First
National City wanted to go into after considerable study.

He doubted

whether the conditions under discussion were worth much as far as
assurance of soundness of operations was concerned.
Governor Mitchell indicated he was not prepared at this juncture
to make a decision on the particular case at hand.

He reiterated that

he thought a memorandum should be prepared that would list restrictions
imposed in connection with the acquisition of shares of foreign banks
in various cases; that list could also cite the general restrictions
imposed by Regulation K.

The matter could then be considered further

from the standpoint of general Board policy.
Governor Daane stated that he, too, thought the Board should
take a look at the restrictions on an over-all basis with a view to
deciding what was being accomplished by them.

It might be, as the

Chairman had suggested, that the whole framework should be liberalized.
After discussion of the urgency of the Banque de l'Afrique
matter, it was understood that a memorandum of the type suggested by
Governor Mitchell would be prepared as a basis for further consideration
Of the problem at tomorrow's meeting of the Board.
The meeting then adjourned.

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-22Secretary's Notes: A letter was sent on
August 31, 1964, to First National City Bank,
New York, New York, acknowledging receipt of
notice of its intent to establish a branch in
the Vallejo District of Mexico City, Mexico.
(The Board approved the establishment of such
a branch on July 25, 1963, but the time limit
for opening the branch expired on August 1,
1964.)
A letter was sent today to The Chase Manhattan
Bank, New York, New York, acknowledging receipt
of notice of its intent to establish an additional branch in the City of Panama, Republic
of Panama, to be located at the corner of Via
Bolivar (Trans-Isthmian Highway) and Fifth
Street in the Industrial Development Area of
Betania District of the City of Panama.
Acting in the absence of Governor Shepardson,
Governor Robertson authorized on behalf of the
Board on August 26, 1964, travel to Ottawa,
Canada, during the period September 10-11, 1964,
by Clayton Gehman, Chief, Business Conditions
Section, Division of Research and Statistics,
for the purpose of meeting with representatives
of the Dominion Bureau of Statistics and the
Bank of Canada.
Governor Shepardson approved on behalf of the
Board on August 31, 1964, the following items:

Letter to the Federal Reserve Bank of New York (attached Item No. 5)
approving the appointment of John J. Goggins as examiner.
Memoranda recommending the acceptance of resignations of the
following persons on the Board's staff, effective as of the dater;
indicated:
Name and title

Division

Date

Legal
Melvin Goldstein, Summer Law Clerk

September

4, 1964

300
9/1/64
Name and title

-23Date

Division
Research and Statistics

Joanne L. Jessup, Statistical Clerk-Typist
James L. Kichline, Summer Research Assistant
Edward H. Rastatter, Summer Research Assistant
Alan K. Severn, Summer Research Assistant
James J. Sullivan, Summer Research Assistant

August 25, 1964
September 3, 1964
September 11, 1964
September 11, 1964
September 11, 1964

Governor Shepardson today approved on
behalf of the Board a memorandum from
the Division of Data Processing dated
August 28, 1964, requesting authorization for payment of approximately $3,000
to the Bureau of the Census this fall
for computer processing seasonal adjustments of bank debits for Standard Metropolitan Statistical Areas. This action
included authorization of the resulting
budget overexpenditure.

Assistant Secretay

,W08
Item No. 1
9/1/64

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON, O. C. 20551
ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

September 1, 1964.

First National City Bank,
399 Park Avenue,
New York, New York, 10022
Gentlemen:
The Board of Governors of the Federal Reserve System grants
its permission to First National City Bank, New York, New York,
pursuant to the provisions of Section 25 of the Federal Reserve Act,
to establish a branch in the City of Port-of-Spain, Trinidad and
Tobago, and to operate and maintain such branch subject to the
provisions of such Section and of Regulation M.
Unless the branch is actually established and opened for
business on or before September 1, 1965, all rights granted hereby
shall be deemed to have been abandoned and the authority hereby
granted will automatically terminate on that date.
Please inform the Board of Governors, through the Federal
Reserve Bank of New York, when the branch is opened for business,
furnishing information as to the exact location of the branch. The
Board should also be promptly informed of any future change in
location of the branch within the City of Port-of-Spain.
Very truly yours,

(Signed) Karl E. Bakke
Karl E. Bakke,
Assistant Secretary.
(The letter to the Reserve Bank stated that the
Board also had approved a six-month extension
of the period allowed to establish the branch;
and that if an extension should be requested,
the procedure prescribed in the Board'r letter
of November 9, 1962 (S-1846), should 13e followed.)

30
Item No. 2
9/1/64

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM
WASHINOTON
OFFICE OF THE CHAIRMAN

September 2, 1964

The Honorable James J. Saxon,
Comptroller of the Currency,
Room 3120, Main Treasury,
20220.
Washington, D. C.
Dear Jim:
The enclosed letter was prepared in response to
Chairman Barr's letter of August 18. It is our understanding
that a similar letter was also addressed to you. As you will
note from the attached letter, Mr. Barr has been informed that
the Federal Reserve Will also use a short form condition report
for the fall call.
No decisions have as yet been made as to tabulating
member bank data from the call, particularly since the form
for national member banks is not compatible with that for State
member and nonmember banks. The limited statistical value of
the fall call does not warrant the use of slip-sheet reconciliation statements or elaborate editing or tabulating procedures.
However, useful tabulations of all member and all insured banks
could be made, without complex and inefficient processing procedures ari recourse to a slip-sheet reconciliation, by the
Inclusion of a minimum number of memoranda items on the national
bank form. Items to reflect (1) the inclusion of securities
purchased under resale transactions and the exclusion of
securities sold under repurchase transactions, (2) corporate
stock holdings included in other assets, and (3) the amount of
mortgages and other liens netted against the fixed asset item
would make the reports entirely compatible and allow tabulation
of summary statistics with a minimum of effort and expense.
Sincerely yours,

Wm. McC. Martin, Jr.
Enclosure

.....

...4.0oFcovt •.

Item No.

BOARD OF GOVERNORS

9/1/64

OF THE

•o
•

1:

FEDERAL RESERVE SYSTEM
WASHINGTON

q•

(0.•
9*•'
.4ALREst-.•

OFFICE OF THE CHAIRMAN

September 2, 1964

The Honorable Joseph W. Barr,
Chairman,
Federal Deposit Insurance Corporation,
20429
Washington, D. C.
Dear Joe:
This is to confirm the understanding expressed in
your August 18 letter that the Federal Reserve also plans to
use a short form report of condition for the fall call date.
We will print and send to the Federal Reserve Banks for distribution to State member banks a call report form identical
with that used as of April 15, 1964.
We have no plans to collect a slip-sheet reconciliation statement from national member banks even if the form to
be used by the Comptroller of the Currency for national banks
is not compatible with the State forms. Plans for tabulation
of all member bank data from the fall condition reports have
not yet been settled. The expense of such tabulations must be
weighed against the potential value of the statistical output
from an incompatible fall call before a final decision is made.
A letter to the Comptroller of the Currency on this subject is
attached.
Sincerely yours,

Wm. McC. Martin, Jr.

Enclosure.

3

t.)
Item No. 11.

BOARD OF GOVERNORS

9/1/64

OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON, D. C. 20551
ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

September 4, 1964.

Mr. Alfred Hayes, President,
Federal Reserve Bank of New York,
New York, New York. 10045
Dear Mr. Hayes:
In its letter of February 10, 1964 (S-1907) the Board reiterated the general principle that "officers and employees of a Federal
Reserve Bank should refrain from placing themselves in any position
that might embarrass the Bank or the Federal Reserve System as a whole
in the conduct of its operations or result in any questions being
raised as to the independence of the individual's judgment or his ability to perform satisfactorily all of the duties of his position with
the System." Subparagraph 5. of that letter specifically referred to
the ownership of bank stocks, as follows:
"5. It would be inappropriate for a member of the staff
of a Reserve Bank to purchase stock of a bank or an
affiliate thereof (except possibly where the actual
relationship of the affiliate to the bank is remote);
officers and employees occupying responsible positions
and holding or acquiring stock of banks or affiliates
should dispose of it as promptly as is practicable
without causing undue hardship."
Among the matters considered by the Board while reviewing the
examination of the Federal Reserve Bank of New York as at May 22, 1964,
were the administrative measures taken in your Bank in the light of the
above paragraph 5., including in particular an exception made in the case
of certain bank stocks owned by Mr. Philip Vachon. The Board's understanding of the Vachon matter may be summarized as follows: Mr. Vachon is a
supervisory employee of the Foreign Department; he has been acquiring bank
stocks over a long period of time to supplement his retirement benefits;
through established reporting procedures, he has periodically informed
the Bank regarding the details of his holdings; in view of the foregoing
circumstances, the Reserve Bank management felt that now to require

a
k

)
_i_Puf

Hr. Alfred Hayes

Mr. Vachon to dispose of his holdings would be in the nature of "undue
hardship," and concluded to allow him to retain the shares he has acquired
to this time.
The Board recognized the special considerations which caused
your Bank to make an exception with regard to Mk. Vachon's present holdings. At the same time, it felt you Should know that there was again
emphasized during the discussion of the subject the Board's concern
about possible conflicts of interest and the responsibility of the
Reserve Banks for taking all reasonable measures to assure that persons
in their employ avoid any relationships that might give rise to questions of such character.
Very truly yours,

Kenneth A. Kenyon,
Assistant Secretary.

BOARD OF GOVERNORS

Item No.

5

9/1/64

OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON, D. C. 20551
ADDRESS OFFICIAL CORRESPONDENCE
TO THE BOARD

September 1, 1964.

Mr. Howard D. Crosse, Vice President,
Federal Reserve Bank of New York,
New York, New York. 10045
Dear Mr. Crosse:
In accordance with the request contained in your
appointment
letter of August 27, 1964, the Board approves the
r, as an
examine
nt
assista
of John J. Goggins, at present an
Please
York.
New
of
Bank
examiner for the Federal Reserve
apthe
of
date
ve
effecti
advise the salary rate and the
pointment.
Very truly yours,
(Signed) Karl E. Bakke
Karl E. Bakke,
Assistant Secretary.