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MINUTES OF MEETING of the FEDERAL ADVISORY COUNCIL November 16-17, 1936 M IN U T E S OF M E E T IN G OF T H E FED ER A L ADVISORY COUNCIL November 16, 1936. The fourth statutory meeting for 1936 of the Federal Advisory Council was con vened in Room 836 of the Mayflower Hotel, Washington, D. C., on Monday, November 16, 1936, at 10:15 A. M ., the President, Mr. Smith, in the Chair. Present: M r. M r. M r. M r. M r. M r. M r. M r. M r. M r. M r. M r. M r. Thomas M . Steele James H. Perkins Howard A. Loeb Arthur E. Braun Charles M . Gohen H. Lane Young Edward E. Brown Walter W . Smith Theodore W old J. J. Thomas (Alternate for Mr. W. T. Kemper) Joseph H. Frost M . A. Arnold Walter Lichtenstein District No. District No. District No. District No. District No. District No. District No. District No. District No. District No. District No. District No. Secretary 1 2 3 4 5 6 7 8 9 10 11 12 On motion, duly made and seconded, the minutes of the Council meeting of September 9-10, 1936, copies of which had been previously sent to the members, were approved. It was decided that the Council should discuss first of all the subjects presented by the Board of Governors of the Federal Reserve System, dealing with Subsections (E) and (F) of Section 1 of Regulation Q. M r. Young presented a memorandum on the desirability of the adoption by the Board of Governors of the Federal Reserve System of a definition of interest in accordance with Subsection (F) of Section 1 of Regulation Q. This memorandum was accepted and made a part of the records of the Council. M r. Young presented a resolution covering Subsection (F). After a lengthy dis cussion it was moved and seconded to adopt the resolution which appears as the first paragraph of Recommendation 2 attached to these minutes. Mr. Loeb asked to be recorded as voting no, all other members voting in the affirmative. At 11:30 A. M . Dr. Goldenweiser, Director, Division of Research and Statistics, appeared before the Federal Advisory Council and discussed the business situation and also in some detail the recent agreement entered into between this country, Great Britain and France regarding their respective currencies, etc. The meeting adjourned at 1:00 P. M . for luncheon at which Chairman Marriner S. Eccles was present. 1 The meeting reconvened in Room 836 at 3:30 P. M. The Council discussed the answers to be made to the Board of Governors to the queries presented to the Council in connection with Subsection (F) of Section 1 of Regu lation Q. The answers appear as part of Recommendation 2 which is attached hereto and made a part o f these minutes. The Council entered upon a discussion of Subsection (E) of Section 1 of Regulation Q and voted unanimously to adopt a recommendation to the Board of Governors of the Federal Reserve System which is attached hereto and made a part of these minutes as Recommendation 1. M r. Arnold presented his views on the competition of government lending agencies in the fanning sections of several of the western states. It was agreed to discuss this problem with Governor Davis and with Governor W. I. Myers of the Farm Credit Administration. A t 4:30 P. M . it was decided to discuss M r. Frost’s memorandum which is attached to these minutes as part of the records. After some discussion Mr. Loeb submitted letters of Professor F. Cyril James, of the University of Pennsylvania, and Mr. Sienkiewicz, of the staff of the Federal Reserve Bank o f Philadelphia, commenting upon Mr. Frost’s memorandum. M r. Steele submitted letters from Professor Ray Bert Westerfield, of Yale University, also commenting on M r. Frost’s memorandum. M r. Steele desired to be recorded as in general accord with the statement presented b y M r. Frost, although not in agreement as to all of its details. It was voted to thank M r. Frost for his work in preparing the memorandum which was accepted and ordered to be made part of the records of the Council. It was decided to ask President Smith to inform the Board of Governors that the Council had discussed inflation and wished to be informed as to the methods which the Board contemplated employing to check such a movement if this became necessary. The meeting adjourned at 6:30 P. M . W A L T E R LIC H TE N STE IN , Secretary. 2 M IN U T E S O F JO IN T C O N FER EN C E OF T H E FED ER A L ADVISORY COUNCIL A ND T H E BOARD OF GOVERNORS OF T H E FED ERA L RESERVE SYSTEM November 17, 1936 At 10:00 A. M . a joint conference of the Federal Advisory Council and the Board o f Governors of the Federal Reserve System was held in the Board Room, Washington Building, Washington, D. C. Present: Members of the Board of Governors of the Federal Reserve System: Chairman Marriner S. Eccles; Vice Chairman Ronald Ransom; Governors Joseph A. Brokerick, Chester C. Davis, John McKee, and M . S. Szymczak; also Messrs. Chester Morrill, Secretary of the Board; L. P. Bethea and S. A. Carpenter, Assistant Secretaries of the Board; Lawrence Clayton, Assistant to the Chairman of the Board; Walter Wyatt, General Counsel for the Board; Dr. E. A. Goldenweiser, Director, Division of Research and Statistics, Board of Governors; Carl E. Parry, Chief of Division of Bank Loans, Board o f Governors; Leo H. Paulger, Chief of Division of Examinations, Board of Governors; George B. Vest, Assistant General Counsel of the Board of Governors; and Elliott Thurs ton, Special Assistant to the Chairman of the Board of Governors. Present: Members of the Federal Advisory Council: M r. Walter W. Smith, President; Mr. Howard A. Loeb, Vice President; Messrs. T. M . Steele, J. H. Perkins, A .E . Braun, C .M . Gohen, H. Lane Young, E. E. Brown, Theodore W old, J. J. Thomas, J. H. Frost, M . A. Arnold, and Walter Lichtenstein, Secretary. The Secretary of the Federal Advisory Council read the recommendation made by the Council in respect to Subsection (E) of Section 1 of Regulation Q which is attached hereto and made a part of these minutes. Vice Chairman Ransom of the Board of Governors discussed the problems involved at some length. The Secretary of the Federal Advisory Council read the recommendation respecting Subsection (F) of Section 1 of Regulation Q which is attached hereto and made a part of these minutes as Recommendation 2. Vice Chairman Ransom discussed this regulation after which a general discussion took place. The President of the Council raised the question of inflation and asked what means could be used to check the drift. In response to a question of Chairman Eccles as to what the Council recommended, the President of the Council called on the various members of the Council to state their views. After this was done, Chairman Eccles stated that he believed: (a) This country should not lend money abroad. (b) Foreign funds should not be accepted in this country. (c) Foreigners should not be allowed to purchase American securities. He expounded these theses at some length and upon his request Dr. Goldenweiser discussed the matter somewhat further. At twelve o ’clock Governor Myers of the Farm Credit Administration joined the meeting and discussed the whole problem of rural credits. He left the meeting at 12:45 P. M 3 In answer to a question raised by Governor M cKee several members of the Council stated that they did not believe that increasing reserve requirements in August had affected the market price of securities. The meeting adjourned at 12:50 P. M . W A LT E R LICH TE N STEIN , Secretary. 4 R EC O M M EN D A TIO N S OF T H E F E D E R A L ADVISORY CO U N C IL TO T H E BOARD OF GOVERNORS OF T H E F E D E R A L R ESER V E SYSTEM November 17, 1936. T O P IC N o. 1. Regarding Subsection (E) of Section 1 o f Regulation Q. R E C O M M E N D A T IO N : The Federal Advisory Council would prefer that the regulation governing savings accounts stand as it is now since most American banks have become adjusted to it. If, however, there is to be a change, the Council prefers that it be in the direction o f greater liberality, and in that case recommends the adoption o f the more liberal interpretation omitting, however, the third clause reading as follows: “ a corporation, association or other organization which is organized and operated for the mutual benefit of its members and transacts more than half o f its business with or for its members, and in respect to which d ep osit. . . T O P IC N o. 2. Regarding Subsection (F) o f Section 1 of Regulation Q. R E C O M M E N D A T IO N : The Federal Advisory Council recommends to the Board of Governors of the Federal Reserve System that it put into effect subsection (F) o f Section 1 o f Regulation Q as proposed by the Board in the memorandum submitted to the Federal Advisory Council under date of October 27, 1936. The Federal Advisory Council answering the queries of the Board in its memorandum of October 27, 1936, addressed to the Council, states the following: 1. If made operative, what effect, if any, would the Board’s definition o f interest have on: (a) Membership in the Federal Reserve System? The Federal Advisory Council is of the opinion there would be no material effect; there might be a temporary one resulting in the withdrawal o f some banks from the System but it is the belief of the Council that in the long run the Federal Reserve System would be strengthened by putting into effect the proposed regulation. (b) Correspondent bank relationships? The Federal Advisory Council believes there would be no permanent adverse effect. 2. Assuming for the purpose of the question in this paragraph that the prohibition against the payment of interest on demand deposits is in the interest o f sound banking practice, does the Council feel that the Board’s definition o f interest would effectuate the purposes o f the statutory provision that such interest shall not be paid, directly or indirectly, by any device whatsoever? The Federal Advisory Council replies in the affirmative. 3 3. T w o opposing views have been presented to the Board on one question connected with this definition. It has been stated that making the definition effective will cause nonmember banks now remitting at par to leave the par list, thus increasing the cost o f banking service to the public. It has also been stated that it will have exactly the opposite effect, and that non-par banks would be forced to remit at par and such banks would be deprived of an important source of revenue. The views of the Council are asked as to which, if either, of these suggested conse quences they would anticipate if the definition were made effective. T he members o f the Federal Advisory Council are divided in their opinion. Some members o f the Council believe that the regulation would drive nonmember banks on to the par list while some are of the contrary opinion. 4. It has come to the attention of the Board that some nonmember banks have withdrawn or are contemplating withdrawal from the par list in order to obtain additional revenue from exchange and collection charges. The Board would ap preciate the Council’s comments as to the extent to which member banks are bidding competitively for accounts of banks or others on the basis of the absorp tion o f exchange and collection charges and its opinion on the question whether the making effective of the definition of interest contained in Reg ulation Q would correct this situation or whether the Board should take some additional action. In a very few of the Federal reserve districts some banks are bidding for accounts on the basis of absorbing exchange and collection charges; in most of the districts, how ever, there is no such competition. The Federal Advisory Council believes the proposed regulation will put a stop to the practice of competitive bidding for accounts of banks or others on the basis o f the absorption of exchange and collection charges. 4 The Desirability Tor the Ado tion by the Board of Governors o f the Federal liecerv© System of a ±>efin itio . of "Interest* ia accordance with Regulation Section 1, Sub-3 ction ?• Since tiie adoption o f the Backing Act o f 1952 Mwtor banks of the Federal Seserve System have been prohibited fr o . aying any interest, d ir e c t ly or in d ir e c t ly , by any d ev ice whatsoever, on any deposit which is payable on demand (*ec* i l - b , Banking net o f 1J33). The is due was taen resented as to whether the ab sorp tion o f o u t-o f-p o c k e t expenses incurred in the c o lle c t io n o f non-par ite& s by a bank f o r i t s de positors con stitu ted an in d ir e c t payment o f in te r e s t which was roh ib ited* Although the Banking ^ct o f i 35 contained no d e fin itio n o f the term " in t e r e s t " , that tern gen era lly s ig n ifie s compensation >aid by a borro?*er fo r the use o f money (Bouvier*s Law Dictionary)# Some o f the *ember Bansa, being o f the opinion that the absorption o f o u t-o f-p o ck e t expense® incurred in the c o llo c t io n of non-par ite c s constituted an i n d r e c t pa acnt of interest, discontinued that Ban*iag c t o f 1955* raetiee upon tae effective date o f the Other ^euber Banks, possibly feeling that a ;ix e u er- centa^e on the amount of deposit would have to be paid to constitute interest, o r that the amount >uid vsould have to be paia direct to the deimsitor, oonti;ue the practice of absorbing out-of-pocket collection expenses* It is submitted that suca absorption is more detrimental to sound bariking ractice ta n the >ayment to depositors o f interest under a specific contract and that the language of the Banking Acts o f 1355 and 1956 proh ibits both p ra ctices with respect to demand deposits* To i llu s t r a t e , in te re st i s paid a t a s p e c ifie d rate on co lle cte d balances (c o lle c t e d ba l nces being those remaining a fte r deduction o f reserves and o<tatanding item s), while exchange that i s absorbed, although bearing a re la tio n to balances, i s not con trolled completely by the amount o f the co lle c te d balance, and the r a c t ic e o f abaorbin*j exchange *<-ay r e s u lt in the W ^ e u t o f in te re st or consideration at a greater rate than would ord in a rily be considered good business practice. As though f o r the express purpose o f remedying th is lack o f uni formity o f p r a c t ic e the Ranking Act o f 1936 conferred express authority upon the Board o f Governors " t o determine what s h a ll be deemed to be a payment o f in terest" (S e c. 524, BarJdLng Act o f 1335) • Regulation Q, Sec# 1 ( f ) as origins ly w ritten i s s u f f ic ie n t ly broad in i t s language to compel a i l Member Banks to adopt the p r a c tic e o f refu sin g to absorb o u t-o f-p o ck e t c o lle c t io n expenses. To f a i l to d efin e in te r e s t under the authority conferred by the Banking Act o f 1935 i s to p en alise Member Banks which endeavor wholeheartedly to comoly with the r e s t r ic t io n s inposed in the Banking Acts o f 1955 and 1956* Failure to adopt the regu la tion s d efin in g in te r e s t to include the absorption o f o u t-o f-p o ck e t expenses w i l l have the probable e f f e c t o f postponing the date on which par clearan ce becomes u n iv ersa l. I t has bean suggested that the postponement o f the e ffe c t iv e date o f sub-section ( f ) o f Sec. 1 o f Regulation Q was caused by the fa ilu r e o f F .D .I.C . to adopt a sim ila r regu la tion which would have been a p p lica b le to insured non-aesber banks* I t has a lso been stated that F .D .I.C . cor,tended that i t lacked a u th ority to ado t a regulation as broad in i t s scope as sub section ( f ) . L*et i t be said here that the au th ority o f the Board o f Governors to determine what s h a ll be deeded a payment o f in te r e s t Is e n tir e ly independent o f any rat io rity con ferred upon the Board o f D irectors o f F .D .I.C *, and that t:ie Board o f Governors is vested with authority to a ct whether or not F*D*I*C* prosaulgates any regu la tion upon the subject* I t i s submitted, however, that the authority o f the Board o f D irectors o f F.D.I*C* is s u ffic ie n t to enable I t to adopt a r#gu in tion id e n tica l in language with the proposed subsection ( f ) o f k c t io a 1 o f Regulation Q, and that even though F .D .I.C . should adopt a - 5 - regu lation d i f f e r e n t fr o i that &do;*tsd by the Board of Governors, the adoption o f iiub-s# e t io a ( f ) by th© iioarsi of Governors would u ltiu u te ly have the e f f e c t o f causing a l l a o n -a ^ b e r banks to ©ease the p ra ctice o f absorbing o u t -o f-p o c k e t ex eases involved ia the c o lle c t io n of i teais on non-par ;joints* tie w i l l cieal f i r n t with the au th ority o f the Board o f Direc tore o f F# D. I* C* Under S ection 101 (v) (y ) o f the Banking Act o f 1351 the Board o f D irectors o f F«D*I*C* was d ire cte d to ir o h ib it *by regulation * * * tiie oayiaent o f In te re s t on demand de >osits in in ured non—sioasber bands’* and fo r juch purposes tiie Board m s given ex ress authority to d efin e the tera ■demand d e p o s it11. I f Congress had not intended to con fer upon the Board o f D irectors tne a u th ority to d efin e the term * KV/iaent o f in te re st* i t would not have d ire c te d the Board o f D irectors o f F. D. X* C. to p ro h ib it b£ regulation the a .,ent o f in te r e s t on denand d e c e i t s * I t ®oald be ne.inhi^Lnss f o r Con ress to con fer any authority upon the Board o f D irectors in t is res e ct to d e s c rib e r e f l a t i o n s i f any regu la tion which th© Board aight adopt could p ro h ib it no tiling which was not proh ibiten by tne i&ugua^e o f tiie Act i t s e l f . Hor could Congress have intended that the Boai\i o f D irectors night at i t s o tion p roh ib it ayment o f in te r e s t on desjaad d e c e i t s sin ce tne language o f the Statute s ta tes th at such Board " s n a il by regulation prohibit® such payment o f in te r e s t. in That the Board o f D irectors o f F .D .I.C . construes the Statute uestion to give i t au th ority to define the tens *in terest* i s evident froa th eir Regulation 4# su b -section 1 ( f ) , in which is found th is language, "the tem •interest* includes any a i r r c t or in d ire ct payment by the bunk o f tha mrch se r ic e o f -rraniuus :'ivon to de o s lt o r s o r prospective dep ositors in connection with obtaining dei^osits*’ . I f the >urchase r ic e o f a ;:re iun given - 4 - to a new depositor conatitutues & payment of Interest, is it not obvious that an agreement on the >art of a bank soliciting new deposit accounts to absorb out-of- ocket expenses in the collection of non-par itests deix>sited in the account is a ls o a prohibited payaent of interest? Suppose fo r th s .orient that F*D*I*C* should f a i l to Adopt a re*a»la tio . sim ila r to the reposed au b-secticu i f ) o f Regulation <** «hat would be th® ef fe c t o f tiia auoptioa by the Board o f uovemors of tne Federal Reserve S y s t e i o f su b -se ctio n ( f ) as o r ig in a lly drawn? ba&ll insured non- ee^ber banks in ou tly in g communities which habitu ally c o lle c t e d non-par items through a ae&ber bank, the la t t e r absorbing o u t -o f -;» c k e t e x p o s e s in con nection with the tra n sa ctio n , would fin d themselves faced with the question o f e ith e r absorbing such expenses themselves o r o f passing the expense on to th e ir de;x>sltors s in c e the oesiber banks, by regulation woulc have been prohibited fr o continuing such absorption# I t might be argued that the s o a il non-jae-iiber bunks had in the _*ast been able to absorb such charges without i l l e ffe c t * however, in the ^ a jo r i t / o f instances the insured non- ae ber bank did not i t s e l f absorb such costs, but was able to pass such charges on to i t s c o lle c t in g bank* It is f e l t that the increased burden o f absorption which would be pi eed upon the insured non-ae&ber banks would be sufficient in nost instances to compel thea to discoatiau® the p ra ctice of absorbing out-of- socket ex tenses incurred la the colifcctioa of non-par itc.iS and to as«» such charges on to their depositors* It night further be argued tnat the ado tion of sub-section (f) by the Federal Heserve board and not by P*D*I*C* sdght affect injuriously a oecber bank located in a town in which there is found an insured n o n -s e b o r competing bank, in that depositors of the zae&ber bank would at once transfer their ccounts to tho non-t&e bcr bank in order to avoid Uie payment of col lsetion charges* This action, i f it occurred, would only have the effect of further reducing the n et warnings o f the aon-iaeaber b&nke o r o f coei e llin g t .e. * to d iscon tin u e the p ra ctice o f absorbing o u t-of-p ock et c o lle c tio n ex leases* I f in d iv id u a l de:>o5 it o r s o f in jured noa-eeruber ban s actu ally f e l t the fin a n c ia l burden in cid en t to the c o lle c t io n o f itezas on non-par join ts i t would tend towards a wider re cog n ition o f the advantages o f un iversal .mivclc&rance and the ultiaiate attainment o f that goal* I t Is respectfully urged that sub-section ( f ) of Section 1 o f Beguletio Q by the Board of Governors of the Federal Reserve System should be &&de of Toll force* ]\Tow t h a t the n a t io n a l p a s t , and c o n s i d e r i n g t h e fa ct, e le ctio n s fu rth er, o f th e F e d e r a l A d v i s o r y C o u n c i l f o r seem t o be an a p p r o p r i a t e its o f November 3 have b e e n th at t h is 1936 t e r m o f o f f i c e , and a d e s i r a b l e t im e f o r d i s p a s s i o n a t e an d n o n - p a r t i s a n , C o u n c il e n t e r t a in s w ith r e s p e c t o f th e money o r curren cy stru ctu re cre d it i s fo r w o u ld a lth ou g h S ystem o f t h e t o th e p re se n t p o s i t i o n o f t h e n a t i o n , w h i c h s e r v e s a s an th e p e o p le o f t h e c o u n t r y and w h ic h f u r f e d e r a l b a n k i n g la w s a s t h e b a s i s u p o n w h i c h a l l b a n k s u p e rim p o s e d . T he C o u n c i l b e l i e v e s p ro b a b ly in d e e d t h e r e is to th e B oard c o n c e r n i n g fo r th e a c le a r , o f the F e d e ra l R eserve v iew s w h ic h t h e a c t u a l medium o f e x c h a n g e it statem en t by the F e d e r a l A d v is o r y C o u n c il t o t h e B o a r d o f G o v e r n o r s ther s e r v e s u n der i s th e f i n a l m eetin g fu tu re w ith In C ou n cil w i l l to make may b e m ore cle a rly ap paren t, co n n e ctio n w it h le g is la tio n In th e bein g a s n e a r l y firs t p la ce , s a tis fa cto ry w h ich is rency in th e U n ite d means m oney o f (o r a sta b le v a lu e in money a s a p p l i e d used re fe r to th e by A . co in its may b e b a s ic have been C o u n cil has of d e cid e d as red eem a b le w o rld v a lu e . p r in cip le s observed to in S ystem . accept as s o u n d m o n e y a s may b e B a r to n H epburn i n h i s o f th e a d van ta geou s, F ed era l R eserve "H is to ry fo llo w s : in ) a th e of C ur "S o u n d m oney c o m m o d ity w h ic h h a s in d e p e n d e n t m ean s m o n ey w h e r e i n c o in a g e it ce rta in th e and w h ich i s m arkets reco m m e n d a tio n s w h ic h t h e seem t o cre a tin g u n q u e stio n a b ly to th e a d e fin itio n S ta te s ," th e e q u a ls b r ie fly a sou n d c u r r e n c y w h ich th e B o a r d may a d o p t th ese m atters. fo r to and t h a t make r e c o m m e n d a t i o n s th e g e n e r a l p o l i c y w h ich th e th at step , d e s ira b le , to reasons w it h r e g a r d t o the b u l l i o n is th e as a p r e l i m i n a r y fo u n d t h a t it an o b l i g a t i o n upon i t , respect order th en th a t of fia t. Sound co m m e rcia l v a lu e Sound m oney as a p p lie d to of paper - 2 or to k e n money o f an y k i n d means t h a t w h ic h i s wherein t h e c o m m e r c i a l v a l u e of its b u llio n r e d e e m a b le in money eq u a ls i t s co in a g e v a l u e . ” The C o u n c i l b e l i e v e s t h a t t h e r e would be v e r y l i t t l e l i h o o d o f an y d i s a g r e e m e n t the s u g g e s t i o n t h a t , be d e s i r a b l e fo r in so f a r as i t o f any s t u d e n t o f money w i t h is th e U n ite d S t a t e s and, c ou n try i n t h e w o r l d , to a d m i t t in g , that o f course, time a r i s e w h ic h c o u l d some v a r i a t i o n on t h e p a r t operate i t s lik e re a so n a b ly p r a c t i c a l , for th at m atter, econom y upon a b a s i s i t w ou ld f o r any o f sound money c i r c u m s t a n c e s and c o n d i t i o n s may fr o m tim e t o ju s tify , o r i n d e e d make a b s o l u t e l y e s s e n t i a l , fr o m s u c h r e q u i r e m e n t , but b e a r i n g i n mind a lw a y s t h e d e s ira b ility o f re v e rtin g , a t as e a r l y a d a t e a s i t w ithou t s e r i o u s d a m a g e a sou n d money s u c h a s d e s c r i b e d i n t h e d e % to may be a c c o m p l i s h e d fin it io n above. W it h o u t a t t e m p t i n g t o g o i n t o a l l t h e r e a s o n s t h e r e f o r , we may f u r t h e r assum e t h a t p r a c t i c a l l y a l l that g o l d , or i t s e q u iv a le n t, which most n e a r l y f u l f i l l s f o r th e U n it e d S t a t e s is i n d i s p u t a b l y t h e m a t e r i a l com m odity the p u rp ose. or fo r sound e c o n o m i s t s w i l l a g r e e In o t h e r w o r d s , an i d e a l money any c o u n t r y w o u ld be a l l g o l d , or pa per cu r re n cy r e d e e m a b le a t a l l t i m e s i n g o l d and r e p r e s e n t i n g an a c t u a l h o ld in g b y t h e T r e a s u r y D epartm ent o f a c o r r e s p o n d i n g amount o f g o l d a v a ila b le f o r t h e r e d e m p t i o n o f t h e c u r r e n c y , w i t h , h o w e v e r , m a c h in e r y a v a ila b le t o fa cilita te n e c e s s a r y or d e s i r a b l e on a s a f e b a s i s and w i t h t h e le a st p o s s ib le e x p a n s i o n and c o n t r a c t i o n d istu rb a n ce. At t h e tim e t h a t t h e F e d e r a l R e s e r v e A c t v/as o r i g i n a l l y acted i n t o lav/ i n 1 9 1 3 , t h i s b a s i c en i d e a seems t o have q u i t e d e f i n i t e l y p r e v a i l e d i n t h e m in d 3 o f C o n g r e s s and a l l t h o s e who p l a y e d any m a t e r i a l part in b r i n g i n g a b ou t t h e le g is la tio n . It is tru e, o f c o u r s e , th at fo r - 3 p ra ctica l pu rposes it is necessary, - in o rd er t o f a c i l i t a t e cash t r a n s a c t io n s o f s m a l l am ounts and f o r t h e p u r p o s e o f making c h a n g e , t o m ain tain an a d e q u a t e amount o f s u b s i d i a r y m oney, w i t h w h ic h t h i s was at t h a t t i m e , an d s i n c e At t h e tim e fia t then has c o n tin u o u s ly been , w e ll s u p p lie d . o f th e passage o f th e F ed era l R eserve A c t , the q u a l i t y o f t h e a p p r o x i m a t e l y 340 m i l l i o n s or g r e e n b a c k s , an d t h e a t le a st o f U n it e d S t a t e s n o t e s , th e o re tica l d e s ir a b ility o f e lim in a tin g them from t h e c u r r e n c y s t r u c t u r e , was g e n e r a l l y r e c o g n i z e d . other hand, it On t h e was e v i d e n t l y b e l i e v e d t h a t t h i s was n o t a s u f f i c i e n t l y large amount t o deem i n g o l d , country endanger the a b i l i t y it b ein g s e n tim e n ta l f e e l i n g be b e t t e r n o t t o o f t h e T r e a s u r y Departm ent t o r e f u r t h e r r e c o g n i z e d t h a t t h e r e m ight s t i l l i n c o n n e c t i o n w i t h t h e g r e e n b a c k s w h ic h i t d istu rb u n le ss a b s o lu te ly e s s e n tia l* those r e s p o n s i b l e fo r that th e 566 m i l l i o n tain ed a f i d u c i a r y be a w o u ld U n q u e stio n a b ly , t h e F e d e r a l R e s e r v e A c t must a l s o have r e c o g n i z e d o f s ilv e r e le m e n t, in c lu d e d in th e c i r c u l a t i o n to th e exten t that it i n 1913 c o n d id not rep re se n t a commodity h a v in g a v a l u e i n t h e m a r k e t s o f t h e w o r l d e q u a l t o i t s v a lu e . P rob a b ly t h i s amount was l i k e w i s e c o n s i d e r e d t o be n o t great m agn itu de t h a t t h e a b i l i t y and, f u r t h e r , it fa ce o f su ch t o redeem i n g o l d w o u ld be e n d a n g e r e d , may h a v e b e e n f e a r e d t h a t any a t t e m p t t o e l e i m i n a t e t h is s i l v e r and s i l v e r c e r t i f i c a t e s w o u ld have i n v i t e d a s t r e n u o u s o p p o s i t i o n t o t h e w h o le r e f o r m p r o g r a m on t h e p a r t In a d d i t i o n t o these con stitu tin g a p o r t io n o f th e o f t h e TTs i l v e r b l o c ” . a b ov e-m en tion ed f i d u c i a r y e le m e n ts, e n t i r e money s t o c k deemed t o be o f s u f to redeem i n g o l d at a l l t i m e s , endanger t h e a b i l i t y t h e r e w ere in c i r c u l a t i o n o f the T rea su r slig h tly over ?50 m i l l i o n o f N a t i o n a l Bank N o t e s s e c u r e d b y Government b o n d s , w h ic h , c o u r s e , do n o t r e p r e s e n t an y com m odity w h a t e v e r . T h ese n o t e s , how - ► -'j f i c i e n t l y m o d e r a te v olu m e as n o t t o - 4 ever, w ere a d d i t i o n a l l y s e c u r e d by a f i r s t a s s e ts o f t h e i s s u i n g b a n k s , there was no d o u b t e la sticity , o f th e ir so th at it so lv e n cy . and paramount l i e n is on th e r e a s o n a b l e t o assume t h a t N e v e rth e le ss, due t o t h e i r to th e d e s ira b ility in a sm u ch a s a d e f i n i t e d e v is e d , bu t w h ic h m ethod i t to d e s c r i b e h e r e . is an a c t u a l g o l d b a s i s , very l a r g e s c a l e movements o f g o l d out ou r p r e s e n t p u r p o s e s o f t h e N a t i o n a l Bank N o t e s , t h e and t h e U n it e d S t a t e s N o t e s , we w e re on e s s e n tia l fea tu re - e la sticity . o f c u r r e n c y on a was v e r y f r e s h i n t h e m inds o f C o n g r e s s and o f a l l b a n k e r s a n d m o n e t a r y e x p e r t s , wise p r e s e n t t h e r e a l i z a t i o n form o f g r a d u a l e l i m i n a t i o n was o f 1 9 0 7 , when h o a r d in g took p la ce , supply f o r t h e p u r p o s e its not n ecessa ry fo r but w i t h o u t t h a t The e x p e r i e n c e o f e lim in a tin g t h is m ethod f o r W ith t h e e x c e p t i o n s i l v e r c o i n and c e r t i f i c a t e s , and u n d o u b t e d l y t h e r e was l i k e o f t h e s e a s o n a l s h o r t a g e s i n th e c u r r e n c y o f m ovin g c r o p s and m e e t i n g sudden o r u n u s u a l o f the co u n try . C le a rly , it was d e s i r a b l e t o have an a u x i l i a r y c u r r e n c y o f an e x t r e m e l y and a u t o m a t i c a l l y e l a s t i c which w ould s m o o t h l y , O bviously, and w i t h o u t s u ch an a u x i l i a r y reason t h a t t h e su fficie n t in t h e F e d e r a l R e s e r v e A c t made p e r f e c t l y c l e a r t h e v ie w o f Congress w i t h r e s p e c t c u r re n cy , - stra in , in cre a s e n a tu re t o meet s u c h demands. c u r r e n c y c o u l d n o t be g o l d , f o r t h e s im p le i n t e r n a t i o n a l movement o f g o l d d o e s n o t t a k e p l a c e w i t h r a p i d i t y t o meet s u c h r e q u i r e m e n t s , a l t h o u g h , run, g o l d w i l l move t o t h e o f c a r r y i n g on t h e b u s i n e s s c o u n t r y w here i t in t h e l o n g i s n e c e s s a r y f o r the purpose o f s u ch c o u n t r y , p r o v i d e d t h e r e a r e no i n t e r f e r e n c e s su ch a s t a r i f f w a l l s , em bargoes, qu ota s, and s u ch o t h e r con triv a n ces. The q u e s t i o n t h e n v/as t o p r o v i d e a m echanism b y w h ic h t h e currency s u p p ly w o u ld a u t o m a t i c a l l y i n c r e a s e as n e e d e d , 3ust as a u t o m a t i c a l l y d e c r e a s e when t h e n e e d had p a s s e d , but w h ic h w ou ld so t h a t it - 5 would n o t becom e r e d u n d a n t and t h u s b r i n g a b o u t an unsound c r e d i t pansion and r i s e in th e p r ic e le v e l. The p l a n w orked out v/as as n e a r l y p e r fe c t as human i n g e n u i t y h a s ever yet d e v is e d , v ic tio n o f th e C o u n c il t h a t w ill, it tion e f f i c i e n t l y and p r o p e r l y a t and i t in i t s a l l tim e s. th e fir m con fu n c The m ethod o f i n c r e a s i n g o f member banks i s o p e r a t i o n , and t h e r e d u c t i o n o f t h e currency s u p p l y a f t e r th e need f o r smooth and a u t o m a t i c , p ro v id e d , above th e market- r a t e fo r fu n d s. is under w ise a d m in is t r a t io n , the c u r r e n c y s u p p l y b y means o f r e d i s c o u n t i n g a s s e t s simple, sm ooth an d f a c i l e ex t h e i n c r e a s e has p a s s e d i s o f course, ju s t as th a t the r e d is c o u n t r a te T he C o u n c i l i s the g e n e r a l p r a c t i c e u n d e r n o r m a l c o n d i t i o n s is o f the o p in io n th at s h o u l d be t h a t t h e r e d i s count r a t e s h o u l d be s l i g h t l y a b o v e t h e m arket r a t e i n s t e a d o f b e l o w , as has been t h e p r a c t i c e always two f o r c e s in th e p a s t . T h e r e w o u ld th e n b e , o f course, o p e r a t i n g u p o n t h e bank s w h ic h w o u ld in d u c e t h e r e duction o f r e d i s c o u n t s an d t h e r e b y t h e r e d u c t i o n rency ro r e s e r v e s c r e a t e d b y r e d i s c o u n t s desire on t h e p a r t o f th e s u p p ly o f c u r - n a m e ly , t h e p e r f e c t l y n a t u r a o f bankers t o a v o id the co n tin g e n t lia b ility of t h e ir endorsem ent u p on r e d i s c o u n t e d p a p e r , a n d , s e c o n d l y , t h e more im p e l lin g d e s i r e to th e F e d e ra l R eserve t o a v o i d t h e paym ent o f i n t e r e s t System a t a h i g h e r r a t e t h a n t h e p r e v a i l i n g of g re a t s i g n i f i c a n c e , as in d ic a t in g of extreme e l a s t i c i t y , that open m arket r a t e . th e r e a l i z a t i o n o f th e d e s i r a b i l i t s o lv e n t currency, f o r no a b so lu te la ck o f e l a s t i c i t y . The C o u n c i l now d e s i r e s t o d i r e c t Board t o c e r t a i n is C o n g r e s s p r o v i d e d a m ethod f o r t h e e l i m i n a tion o f the N a t i o n a l Bank N o t e s , a p e r f e c t l y other r e a s o n th a n t h e i r It the a t t e n t i o n o f the im p o r t a n t a c t i o n s w h ic h have been t a k e n , w i t h c o r r e s pondingly im p o r ta n t r e s u l t s . The f i r s t o f t h e s e a c t i v i t i e s w h ich t h e Council d e s i r e s t o m e n t io n was t h e a c c u m u l a t i o n by t h e F e d e r a l R e s e r v e - 6 Banks o f Government o b lig a tio n s of course, e i t h e r in the re su lte d Federal R eserve n o t e s Reserve Banks t o t h e among t h e i r a s s e t s . issu a n ce or in a d e p o s i t cre d it o f an e q u i v a l e n t amount o f on t h e b o o k s o f th e F e d e r a l o f th e re se rv e account The Board d o u b t l e s s v / i l l r e c o g n i z e T h ese p u r c h a s e s , o f t h e member b a n k s. t h e a n a l o g y w h ic h e x i s t s Federal R e s e r v e n o t e s and t h e member bank r e s e r v e d e p o sits, b e tw e en sin ce they either s e r v e a s a medium o f e x c h a n g e i n t h e hands o f t h e p u b l i c a base upon w h ic h bank c r e d i t to c r i t i c i s e the pu rchase may b e i s s u e d . nature where s u c h a c t i o n with m o d e r a t io n , seem s t o ease c o n d it io n s order to currency or an e n la r g e m e n t ments o f t h e moment. s a l agreement w i t h t h e o f the i s used o f the o p in io n that g rea t a v o id th e c r e a tio n by the o f an em ergen cy be i m p e r a t i v e and w here i t but th e C o u n c il i s should be e x e r c i s e d i n The C o u n c i l d o e s n o t w is h o f Governm ent bon ds o r b a n k e r s 1 b i l l s Federal R e s e rv e S y s te m i n o r d e r t o o r as care o f a r e d u n d a n cy o f c r e d i t base beyond th e a c t u a l r e q u i r e The C o u n c i l b e l i e v e s t h a t t h e r e v /ou ld be u n i v e r o p in io n th at th ere is a t t h i s tim e a s u f f i c i e n t quantity o f g o l d i n t h e U n i t e d S t a t e s t o s u p p o r t any c r e d i t e x p a n s io n which i s c o n c e i v a b l e a s a d e s i r a b l e o r ev en a p o s s i b l e one w i t h i n any r e a s o n a b le l e n g t h one, o f t i m e , w i t h o u t making u s e o f an y o f t h e c r e d i t base c r e a t e d by t h e h o l d i n g s o f Government o b l i g a t i o n s b y t h e F e d e r a l Reserve System . N ext, th e C o u n c il w ish e s t o d i r e c t th e a t t e n t i o n to the f u r t h e r im pairm en t increase o f t h e h o l d i n g s o f t h e B oarc o f t h e q u a l i t y o f t h e money s t r u c t u r e b y t h e of s ilv e r b y t h e T r e a s u r y D e p a rtm e n t, a g a i n s t which th e r e a re o u t s t a n d i n g a t t h i s t im e a p p r o x i m a t e l y a b i l l i o n garter d o lla rs in s i l v e r c e rtifica te s . Council th a t t h e s e c e r t i f i c a t e s 0 1 an o u n c e , It and a i s t h e u n d e r s t a n d i n g o f th e are is s u e d a g a in st v/h erea s t h e p r e s e n t m arket v a l u e s ilv e r on t h e b a s i s of s ilv e r i s ap~ p r o x im a t e ly 4 4 ^ c e r tific a te th er, it ou n ce, dependent s h o u ld p r e v a ilin g an in above what i t huge p r o g r a m of in if s ilv e r Government p r o m i s e . (if of fo r It is S ta te s so th a t a ccu m u la tin g is a stock th ere is a very s i l v e r w h ic h h a s b e e n c o in e d been i s s u e d , th is and t h a t the T r e a s u r y D e p a r t m e n t , s ilv e r c e r t i f i c a t e s at fo r is is s u a n c e th e r a te ca rrie d it co n s is tin g a v a ila b le , ury D epartm ent h a s n e v e r b e e n c l e a r l y re v e a le d to and volum e o f s i l v e r is o n e -th ird th e u n d ersta n d in g o f s ilv e r o f the b u llio n se n io ra g e have d o lla rs The C o u n c i l i s b u llio n h e ld or not by t h e T r e a s the p u b li c , a p p ro x im a te ly estim a te i t of even fr o m t h e p r i c e p u r c h a s e s m ade. a t t e n t io n o f t h e B o a r d i s th e Treasury D e p a rtm e n t, w h ic h i s s ta b iliz a tio n t h e b a la n c e o f t h e s o - c a l l e d "g o ld p r o f i t r o f a l l N a t i o n a l Bank N o t e s , and w h ic h , i t that t h is fu n d h a s n o t y e t g o n e i n t o th e fu n d i n t h e hands o f t h e stood , amounts now t o a p p r o x im a t e ly tv/o b i l l i o n that i t i s on ce rtifica te s The n e x t m a t t e r t o w h ic h t h e C o u n c i l w is h e s t o d i r e c t a fte r th e r e t i r e m e n t in at th e d is c r e t io n an o u n c e . s ilv e r to equal to i n th e form o f s i l v e r o f $ 1 .2 9 d o lla r s . It is t h e a c t u a l m oney s t r u c t u r e , i s u n der tru e in in th e h an ds o f t h e T r e a s u r y D epartm ent and n o t y e t a v a i l a b l e ./ out w it h r e g a r d t o o f s ilv e r inform ed as t o v/hy t h e am ount o f t h i s though i t may b e p o s s i b l e e m b a rk e d on t h e i r la rg e r p ercen tage o r a g a i n s t w h ich s i l v e r b u llio n co n s id e ra b ly i n m in d t h a t t h e s i l v e r l a r g e amount the hands o f t h e T r e a s u r y D e p a r t m e n t F ur be r e g a r d e d a s d e p e n d e n t u p on our s o l d h o l d i n g s ) h a v e - o n l y j u s t begun. R a t h e r , o f th e C o u n c i l t h a t s ilv e r G o v e r n m e n t. p ro b a b ly had n ot be b o r n e o f C ongress o f each o f 4 4 -1 / an o u n c e now an e v e n m ig h t p r o p e r l y s h o u ld a l s o o f th e th e p r ic e silv e r U n ite d pu rchases, t h e m andate the r e q u i r e m e n t m in d t h a t th e c e rtifica te s tw o -th ir d s u p on t h e p r o m is e w o r ld m a rk ets w o u ld be o f th e s i l v e r p u rch a s e s s o le ly be b o r n e th e t h u s m a k in g a l m o s t of - 8 for use i n m e e t i n g t h e o p e ra tin g i s , h ow eve r, a v a i l a b l e fo r e x p e n d itu re s the purpose o f t h e G overnm ent. It o f p u r c h a s i n g Government b o n d s , which w ould d e f i n i t e l y p u t t h e w h o le amount i n t o t h e money s t r u c t u r e . It i s h a r d l y c o n c e i v a b l e t h a t two b i l l i o n d o lla rs the hands o f t h e T r e a s u r y D epartm ent w it h o u t ing the t e m p t a t i o n t o o g r e a t amount o f money f o r course, it w ill Assum ing t h a t i t and r e s e r v e s the hands o f t h e F e d e r a l R e s e r v e S y s tem . it s h o u l d be u s e d f o r end up i n t h e money s t r u c t u r e , w h i c h , i n c l u d e s money i n c i r c u l a t i o n gold, and sound m oney, some A d m i n i s t r a t i o n f i n d f o r them t o r e s i s t u s i n g t h i s trem en d ou s some p u r p o s e . any pu rpose w h a t e v e r , ca n a lw a y s rem ain i n of o f member banks i n Even t h o u g h t h i s w o u ld be c o u l d be t h e b a s i s fo r an i n o r d i n a t e and w i l d c r e d it i n f l a t i o n . The C o u n c i l d o e s n o t w is h t o t a k e t h e p o s i t i o n t h a t every thing which h a s b e e n don e i n c o n n e c t i o n w i t h ou r m o n e ta r y a c t i v i t i e s has been w rong. On t h e c o n t r a r y , passed t h r o u g h an e m e r g e n c y , it d e s i r e s t o r e c o g n i z e t h a t we have o r s e v e r a l e m e r g e n c i e s , and t h a t t h e things w hich h a ve b e e n don e h a ve seemed t o t h o s e i n a u t h o r i t y t o be p r o per and n e c e s s a r y . purpose o f e i t h e r In o t h e r w o r d s , t h i s con d em n in g o r p r a i s i n g s t a t e m e n t i s n o t made f o r past a c t io n s , but p u r e l y f o r the c o n s i d e r a t i o n o f t h e B o a r d i n c o n n e c t i o n w i t h t h e i r respect t o f u t u r e p o l i c i e s a ffe ctin g In c o n s i d e r i n g t h e f u t u r e opinion t h a t human n a t u r e , 2x 4 '<’ i that a v a i l a b l e orris, th e b a n k s , in i t s d e c is io n w ith t h e money and r e s e r v e stru ctu re. o u t lo o k , the C o u n cil i s b a s ic c h a r a c t e r is t ic s , c r e d i t w i l l u l t i m a t e l y be pu t t o u s e . w ith r e t u r n i n g co n fid e n ce , o f the has not change i In o t h e r ' , w i l l be w i l l i n g t o in cre a s- th eir lo a n s and d e p o s i t s t o t h e u l t i m a t e amount l e g a l l y p o s s i b l e any giv en c r e d i t th e on b a s e , and t h e b u s i n e s s men and p u b l i c g e n e r a l l y , w i t h returning c o n f i d e n c e , v / i l l a v a i l th em selv es o f the d i s p o s i t i o n of -9tanlcers t o e x t e n d c r e d i t , ^e0t that a ba n k c r e d i t so t h a t , i n t h e e n d , we can r e a s o n a b l y e x - or bank d e p o s it £ s t r u c t u r e w i l l be b u i l t up t o tiie l e g a l l i m i t . In s u p p o r t ,al l the a t t e n t i o n taken p l a c e o f th is a ssu m p tio n , o f th e Board t o in t h e bank c r e d i t from g o ld i m p o r t s a n d s i l v e r siaSj^governmental d e f i c i t s On June 30, 1933, tota l to 9 5 7 , 9 9 8 , 0 0 0 , 0 0 0 . 0 0 , some d e g r e e fro m o t h e r l o a n s and i n v e s t m e n t s . a n d on June 3 0 , that to o t h e r th a n i n t e r b a n k d e p o s i t s amounted an in cr e a s e o f $ 1 3 , 3 3 7 , 0 0 0 , 0 0 0 . 0 0 the C oun cil b e l i e v e s r e su ltin g p u r c h a s e s b u t p r e p o n d e r a n t l y from f i n a n - an d a l s o in m ight be w o r th w h i l e t o t h e g r e a t e x p a n s i o n w h ic h has a l r e a d y stru ctu re, d e p o sits plete c o n f i d e n c e was n o t it or 35$. ev id e n ce th e 1936, t h e y w ere $ 5 1 , 3 3 5 , 0 0 0 , 0 0 0 , B e a r i n g i n mind t h a t com t h r o u g h o u t t h e w h ole o f th e p e r i o d , te n d e n cy t o put a v a i l a b l e cre d it t o work is c l e a r l y e v i d e n t . A s s u m in g , available c r e d i t th en , the correctn ess w i l l u l t i m a t e l y be u s e d , o f th e s ta te m e n t t h a t t h e C o u n c i l w is h e s t o p o i n t out to the B o a r d t h e a p p r o x i m a t e p o s i t i o n o f t h e b a n k in g and r e s e r v e * structure w h ic h c o u l d c o n c e i v a b l y r e s u l t . On June 3 0 , 19 2 0 , deposits o f member b a n k s w e r e $ 1 , 8 3 9 , 0 0 0 , 0 0 0 . 0 0 and d e p o s i t s than in te r b a n k o f a l l b a n k s we r e § 3 7 , 7 2 1 , 0 0 0 , 0 0 0 . 0 0 a r a t i o On December 3 1 , 1923, *542,163,000,000.00, a r a tio o f 22 t o On D ecem b er 3 1 , clearly d e m o n s tra te t h e fa ct Member ba n k s to tota l On December 3 1 , o f 20 to 1 . 1928, 1926, § 5 0 * 1 - 5 5 ,0 0 0 ,0 0 0 . 0 0 , a r a tio o f 2 3 .5 to o f d e p o sits reserves re a ra tio r e s e r v e s were $ 2 , 4 0 9 , 0 0 0 , 0 0 0 . 0 0 1. T h ese f i g u r e s t h a t u n d e r n orm al c o n d i t i o n s suppose a r a t i o R erbank d e p o s it s , 1. and d e p o s i t s *£4 d e p o s i t s £ 5 6 , 7 6 6 , 0 0 0 , 0 0 0 . 0 0 , R ea son a b le to oth er r e s e r v e s w e re § 1 , 9 0 0 , 0 0 0 , 0 0 0 . 0 0 and d e p o s i t s serves were § 2 , 2 1 0 , 0 0 0 , 0 0 0 . 0 0 °? 22.7 t o 1 . reserve o f a l l banks, it i s not e x clu d in g o f member banks o f a t l e a s t now h a ve t o t a l r e s e r v e s o f $ 6 ,7 5 0 ,0 0 0 ,0 0 0 .0 0 . 20 Assuming no l o s s or g a in o f g o ld , of $1,£ 5 0 ,0 0 0 ,000,00 tifica te s Congress i s ca rrie d the s t a b i l i z a t i o n o u t), an i n c r e a s e o f s ilv e r ( t h e minimum i f and an i n c r e a s e d o lla rs or c e r t h e p u r c h a s e mandate o f of $2,000,000,000,00 from f u n d , member banks w o u ld have $ 1 0 , 0 0 0 , 0 0 0 , 0 0 0 . 0 0 r e s e r v e s up on w h ic h a d e p o s i t $ 2 0 0 , 0 0 0 , 0 0 0 , 0 0 0 .0 0 , stru ctu re co u ld r e s u lt * o f a l l b a n k s , am ounting t o Even i f t h e B oard o f G o v e r n o r s o f the F e d e r a l R e s e r v e S yste m s h o u l d i n c r e a s e r e s e r v e r e q u i r e m e n t s t o t h e maximum p e r m i t t e d b y la w , t o t a l d e p o s i t s The f i r s t fig u re i s n e a r ly fo u r tim e s, dou ble, t h e p r e s e n t that a v a i l a b l e d e p o sit stru ctu re; co u ld go t o $ 1 0 0 , 0 0 0 , 0 0 0 , 0 0 0 .0 0 and t h e s e c o n d f i g u r e n e a r l y b u t , a s s u m in g , as we h a ve d o n e , c r e d i t w i l l u l t i m a t e l y be u s e d , t h a t t h e T r e a s u r y D e p a r t ment w i l l p e r f o r m t h e mandate o f C o n g r e s s w i t h r e s p e c t t o s i l v e r , and that some A d m i n i s t r a t i o n w i l l make u s e o f t h e $ 2 , 0 0 0 , 0 0 0 , 0 0 0 . 0 0 o f gold l y i n g u n u s e d i n t h e T r e a s u r y , n o t h i n g l e s s w i l l r e s u l t . case, i t is d iffic u lt to im a g in e t h e exten t o f the r i s e in the p r i c e l e v e l , t h e e x t r e m e l y s p e c u l a t i v e a c t i v i t y w h ic h w i l l p r e v a i l , d i f f i c u l t y w h ic h t h e w a g e - e a r n e r w i l l h a ve i n s e e i n g t o come w i l l i n c r e a s e w i t h s u f f i c i e n t anything l i k e h i s p r e s e n t it a l l , a f t e r the c r e d it the c u r r e n c y s t r u c t u r e element i n c l u d e d in th e ra p id ity to sta n d ard o f l i v i n g . In su ch it the that h is in e n a b le him t o m a in t a in And t h e n , at t h e end o f i n f l a t i o n h a s t a k e n p l a c e and a new f e a r of s h o u l d d e v e l o p , w i t h t h e tre m e n d ou s f i d u c i a r y s ilv e r d o lla rs and s i l v e r c e r t i f i c a t e s , e q u a lly tre m e n d o u s g o v e r n m e n t b o n d - h o l d i n g s and t h e o f th e F e d e ra l R eserve System, what p o s s i b l e m eth od c a n be t a k e n t o s u c c e s s f u l l y cope w ith the s it u a t io n ? The C o u n c i l h a s a t t e m p t e d t o d e p i c t ab ov e t h e p o s s i b i l i t i e s inherent i n a p o l i c y o f lib e r a l cre d it and lo w r a t e s w it h o u t r e g a r d t o the r i s k s i n v o l v e d i n b u i l d i n g bank c r e d i t sound b a 3 e . The C o u n c i l h a s no v o t e on a n y t h in g o t h e r th a n a o f d i s a p p r o v a l f o r a p o l i c y o f lo w - 11 in t e r e s t rates and p r o v i d e d , or lib e ra l fu rth e r, such & r a p i d r a t e Board w h i c h , if bank c r e d i t o f a ll th e it above, to cre d it soever c u r b o r i n t e r f e r e it w ith or to it in the c r e d i t b a s e stress or in sound in d u c e d the p r i c e m ovem ent t o e s s e n tia lly or causes built a bank d e p o s i t (2 ) o p in io n t h a t , stru ctu re P a r tia lly f o l l o w i n g i t s r e co m m e n d a tio n s t o th e w ill ten d to in that a v o id any d e g r e e w h at it does not In deem c o u ld c o n c e iv a b ly co n d itio n * the C o u n cil to be a l l o f e lim in a tin g a ba n k d e p o s i t th ree T h is v e r y e li m in a t e unsound e le m e n ts or n e c e s s it y the them stru ctu re im p o s e d The r e c o m m e n d a t io n s elem e n ts in fla tio n a r y . of the F e d e r a l R e s e r v e S y s t e m . o f the to its such a c t io n reduce ca n be d a n g e r o u s , the C o u n cil w i l l be w i t h r e s p e c t th at c o n n e c t io n w ith any o f i t s upon them s h o u l d becom e an a c c o m p l i s h e d f a c t . o f the cre d it base, ( 1 ) G overnm ent b o n d - h o l d i n g s S ilv e r. (3 ) if s h o u l d be p e r m i t t e d t o th ere of S ta b iliz a tio n fu n d . t o t h e u l t i m a t e amount w i t h o u t a t be le a st r e c o m m e n d a tio n s w i t h r e g a r d t o t h e s e t h r e e ^ems, v/e may l o o k i n t o t h e fu tu re, p o s s ib ly ra th er d ista n t bu t p o s s i b l y not so fa r away, t o a tim e v/hen v/e c a n e x p e c t an e c o n o m ic c o l l a p s e //r‘ich cou ld be i n c o n c e i v a b l e is e x p a n s io n and r e c o v e r y . even c h a o t ic in a g r a d u a l and a p p r o p r i a t e way b e f o r e The C oun cil i s in C ou n cil b e lie v e s the p o in t that more im p r e s s e d w i t h t h e d e s i r a b i l i t y each o f v/hich i s base be n o t ris e sh o u ld n o t sound c r e d i t re a liz e s create an e x t r e m e l y d i s t u r b e d fa c t , t h a t a d e f i n i t e but sudden a c t i o n s in ce th e d iscre tio n , in fla tio n w ish e s ad visa b le a d r a s t i c recom m endations, e x p a n sio n make d e f i n i t e fo llo w e d w ith w ise p la ce , th e u n d e rly in g an u n s o u n d a n d s p e c u l a t i v e re q u ire dangerous o r w i l d the f i r s t th e p ro v id e d co n co m ita n t. In v i e w statu tory d u t i e s th at th at le v e l i s a n a t u r a l cre d it, in i t s d e v a sta tio n . at - 12 Government b o n g - h o l d i n g s . The C o u n c i l b e l i e v e s t h a t t h e s e s h o u ld be r e d u c e d t o an amount n ot more th a n $ 4 0 0 , 0 0 0 , 0 0 0 * 0 0 b y g r a d u a l s a l e to be p a id as t h e y m a tu re w i t h o u t should ad opt s u ch a p o l i c y , caution t h a t no s e r i o u s it o r p e r m i t t i n g them r e p l a c i n g by p u rc h a s e . I f th e B oard' c o u l d be done g r a d u a l l y and w i t h sueh d islo ca tio n ing th e s e h o l d i n g s by tw o b i l l i o n s h o u ld r e s u l t . d o lla rs , Even a f t e r r e d u c some e x c e s s r e s e r v e s w o u ld remain w it h o u t t h e a c c u m u l a t i o n o f any r e d i s c o u n t s fr o m member b a n k s . S ilv e r The p u r c h a s e s o f s i l v e r s h o u l d be d i s c o n t i n u e d e n t i r e l y , which cause no d e c r e a s e w h a t e v e r i n t h e money s t o c k o r c r e d i t a d d itio n , h o w e v e r , t h e s i l v e r the emergency p u r c h a s e c e rtifica te s base. o u t s t a n d i n g as a r e s u l t In of s h o u l d g r a d u a l l y be r e t i r e d and t h e c o r r e s p o n d ing s i l v e r be s o l d i n t h e m a r k e t s o f t h e w o r l d . could not be done p r e c i p i t a t e l y , might be n e c e s s a r y t o a v o i d bu t T h i s s h o u l d n o t and s h o u l d be done a s g r a d u a l l y a s s e r i o u s d i s t u r b a n c e and s h o c k . Even com p le tio n o f t h e o p e r a t i o n w o u ld l e a v e some $ 6 0 0 , 0 0 0 , 0 0 0 . 0 0 o f s i l v e r d olla rs and c e r t i f i c a t e s i n t h e money s t r u c t u r e e x clu siv e o f su b sid ia ry coin. S ta b iliz a tio n Fund R e a l i z i n g t h e p r a c t i c a l c e r t a i n t y t h a t two b i l l i o n in g o ld cann ot p e r m a n e n t l y b e l o c k e d up i n t h e v a u l t s and b e l i e v i n g t h a t an i n j e c t i o n d o lla rs o f the T rea su ry, o f s u c h an amount o f a d d i t i o n a l money into the c r e d i t b a s e w o u ld p r o d u c e a v e r y d a n g e r o u s and extrem e c r e d i t in fla tio n , even t h o u g h b a s e d on g o l d , t h e C o u n c i l b e l i e v e s t h a t i t ^onld be in e v e r y way d e s i r a b l e t o r e v a l u e u p w a r d ly t h e g o l d c o n t e n t the d o l l a r t o s u c h an e x t e n t t h a t t h e e n t i r e sta b iliz a tio n Y;oiil(i be a b s o r b e d i n t o t h e money s t r u c t u r e w it h o u t i n c r e a s i n g fu nd or de c e a s i n g th e volum e o f t h e money s t r u c t u r e as e x p r e s s e d i n d o l l a r s . - IS - Such a c t i o n w o u ld be i n n o way d e f l a t i o n a r y o r i n f l a t i o n a r y , eliminate a p o t e n t i a l country w ith a g o l d source stock o f cre d it I n f l a t i o n and i t w ou ld l e a v e th e o f n in e b i l l i o n increase or d e c r e a s e t h e p r e s e n t c r e d i t A ssum ing t h a t time a l l be s u c c e s s f u l l y th ese th ree base. c o m p l e t e d , t h e member bank r e s e r v e s w o u ld be two b i l l i o n secon d , and n o t h i n g a t a l l b y t h e t h i r d . d o lla rs by the of member banks a m o u n tin g t o b i lli o n d o l l a r s , d o l l a r s b u t w o u ld n e i t h e r recommended o p e r a t i o n s c o u l d i n redu ced a deposit s t r u c t u r e but w o u ld firs t, fo u r b i l l i o n s e v e n h u n d red m i l l i o n b y t h e T h e r e w o u ld rem ain r e s e r v e s d o lla rs , enough t o support o f a l l b a n k s i n t h e amount o f more th a n e i g h t y o r an i n c r e a s e o f tw e n ty -fiv e b illio n d o lla rs , n ea rly 50$ above th e p r e s e n t v o l u m e , w h ic h i s now a p p r o x i m a t e l y t h e maximum for a l l tim e i n t h e p a s t . I t w o u ld seem t h a t t h i s w o u ld be more th a n enough r e s e r v e s t r u c t u r e t o s u p p o r t any d e s i r a b l e Farther, i t i n mind t h a t t h e b a s e w i l l be a c o m p a r a t i v e sh o u ld be b o rn e ly sound b a se c o n t a i n i n g cre d it e x p a n sio n . o n l y a r e a s o n a b l y m o d e r a t e amount o f G o v e r n ment bonds, g r e e n b a c k s and s i l v e r , so t h a t i f we s h o u l d have s u c h c r e d i t expansion as c o u l d b e s u p p o r t e d u p on i t , then, i f th e b a la n ce o f i n tern ational paym en ts s h o u l d t u r n a g a i n s t t h e U n it e d S t a t e s , sold e x p o r t s and t h u s m aking n e c e s s a r y a r e d u c t i o n ca u sin g o f o u t s t a n d i n g bank credit, the b low c o u l d b e c u s h i o n e d b y l i b e r a l r e d i s c o u n t p r i v i l e g e s teing extended b y t h e F e d e r a l R e s e r v e System - o r ev e n a r e p u r c h a s e - oh amount o f Governm ent o b l i g a t i o n s as m ight seem t o be e s s e n t i a l . How as t o t h e means a v a i l a b l e t o t h e Board f o r b r i n g i n g &bout f a v o r a b l e a c t i o n upon t h e re co m m e n d a tio n s o f t h e C o u n c i l . -oarfi. a lr e a d y has c o m p l e t e a u t h o r i t y t o a c t upon t h e f i r s t recom m enda- tj^ n , c o n c e r n in g t h e h o l d i n g s o f Government Council r e a l i z a e s t h a t a c t i o n on t h e s e c o n d and t h i r d r e c o m m e n d a t io n s , o b lig a tio n s , The but th e I - 14 (jonceiTJa^g s i l v e r a n d t h e s ta b iliz a tio n brought ab ou t b y l e g i s l a t i v e a c tio n fu n d , r e s p e c t i v e l y , ca n o n ly be o f C on gress. The f i r s t tion t h e r e f o r e n e e d s no f u r t h e r comment fr o m t h e C o u n c il., to repeat t h a t a c t i o n recom m enda o t h e r th a n s h o u l d b e t a k e n w i t h g r e a t c a r e and t h a t t h e prooess s h o u ld b e g r a d u a l . E ven t h o u g h a c t i o n on t h e s e c o n d and t h i r d recommendations c a n o n l y b e t h r o u g h t h e medium o f c o n g r e s s i o n a l l e g i s l a tion, the C o u n c i l d e s i r e s t o c a l l the a t t e n t io n o f t h e B oard t o fact th at t h e s o u n d n e s s o f t h e c u r r e n c y and r e s e r v e s t r u c t u r e th e o f the nation may becom e o f pa ra m ou n t im p o r t a n c e i n c o n n e c t i o n w i t h p r e s e r v ing the s a f e t y o f t h e s a v i n g s o f t h e p e o p l e t and t h e C o u n c i l b e l i e v e s that i t i s t h e d u t y o f t h e B o a r d t o g i v e c o n s i d e r a t i o n t o a n y m a t t e r s which may h a ve an e f f e c t thereupon . The C o u n c i l i s o f t h e o p i n i o n t h a t t h e r e s h o u l d a lw a y s be the c l o s e s t r e l a t i o n s h i p an d t h e f u l l e s t c o - o p e r a t i o n b e tw e e n t h e Board o f G o v e r n o r s o f t h e F e d e r a l R e s e r v e S ystem and t h e U n i t e d S t a t e s Treasury D e p a rtm e n t, an d i t b e l i e v e s t h a t t h e B oard o f G o v e r n o r s i n their r e l a t i o n s w i t h t h e T r e a s u r y D epartm ent s h o u l d , i n w h a t e v e r way nay seem a p p r o p r i a t e t o t h e m , g i v e t h e b e n e f i t Department, a s w e l l a s i n q u i r e o f t h e i r v ie w s t o t h a t in t o th e v ie w s o f the T re a su ry D epart ment upon su ch i m p o r t a n t s u b j e c t s a s t h o s e m e n t io n e d a b o v e . Treasury Departm ent i n t u r n , The o r e v e n i n c o n j u n c t i o n w i t h t h e B oard o f Governors o f t h e F e d e r a l R e s e r v e S y s te m , i n t h e o p i n i o n o f t h e C o u n c i l , may with e n t i r e p r o p r i e t y make r e p r e s e n t a t i o n s t o t h e a p p r o p r i a t e committees o f C o n g r e s s , w i t h a v i e w t o priate t o sound and d e s i r a b l e The e s s e n c e e ffe ctin g le g is la t io n appro en ds. o f t h e th o u g h t w h ich t h e C o u n c il w is h e s t o c o n - ?ey to the B oard i s t h a t t h e B oa rd s h o u ld w ork t o t h e end o f a c c o m p lis h - -15 i n g so much o f t h e may be p o s s i b l e , o b je c tiv e s em b o d ie d i n t h e s e r e com m en d a tion s as and t h e C o u n c i l s u g g e s t s c o l l a b o r a t i o n w i t h t h e Treasury D epartm ent a s t h e most n a t u r a l and f e a s i b l e p r o c e d u r e . The C ou n cil, h o w e v e r , b e l i e v e s t h a t t h e r e d u c t i o n o f t h e c r e d i t b a s e i n volved i n t h e g r a d u a l d i s p o s i t i o n the System i s o f Government o b l i g a t i o n s h e l d by o f pa ra m ou n t i m p o r t a n c e , a n d , w h i l e a t a l l t im e s c l o s e c o - o p e r a t i o n w i t h t h e T r e a s u r y d e p a r tm e n t s h o u l d be m a i n t a i n e d , t h e Board ca n n ot a f f o r d t o f a i l t o take should be n e c e s s a r y t o do s o i n o r d e r t o p r e s e r v e t h e s a f e t y o f t h e money and b a n k in g s t r u c t u r e . sound, in d e p e n d e n t m easure i f it Ray Sert Westerfield professor of P o l i t i c a l Economy jfoven, Connecticut, November 10, 1956 Yale U n iversity fcr. Thomas tt. Steele, President, The F ir s t N a tio n a l Bank & T ru s t C o . , jjew mven, C o n n e c t ic u t . Dear Tom: I have gone o v e r th e F r o s t m a n u scrip t and w i l l comment p a r a era?h by paragraph r a t h e r than a tte m p t a com plete re sta te m e n t o f th e p r o u n c e nent. I t i s , as I s a i d i n e a r l i e r l e t t e r , an ad m irable sta tem en t which I could scarcely improve upon. m y Page 2 . P ar. 2 : I r e p e a t my statem ent o f th e f a c t th a t F r o s t masses from Hepburn’ s d e f i n i t i o n o f "sound money" i n t h i s paragraph. Hepburn 7-as content th at th e "paper money" o r "token money 11 was i f i t was "redeem able in money " h e r e in the com m ercial va lu e o f i t s b u l l i o n equals i t s co in a g e v a lu e " but Frost in t e r p r e t s t h i s t o mean "pap er curren cy redeemable a t a l l tim es in and representing .an .actual h o ld in g by" t h e .. t o f a. c o r resp ondi ng --Q-int o f gold a v a i l a b l e f o r the redem ption .of the c u r r e n c y . Now t h i s portion is in a d d it io n t o the Hepburn d e f i n i t i o n , and means th a t o n ly " g o ld c e r t i ficates" are sound. I do n o t b e l i e v e th a t Hepburn meant that l i m i t a t i o n ; he d id not say so; he d id n o t say th a t he wanted 1 0 0 $ r e s e r v e a g a in st a l l paper money. All he 7/anted, and a l l th a t was o r i s n ecessa ry i s th a t a r e s e r v e s u r e ly s u f ficient to provide f o r redemption in g o ld be k e p t . The very f e d e r a l r e s e r v e n o te s which the new Federal Reserve A ct p ro v id e d f o r 7/ere t o be p r o t e c t e d , n o t by reserve, but 4C$ in ordin ary tim e s, l e s s in em ergencies. s o u n d g T r e a s u r y V e m r i n e o l d n u n d e r s c o lQ O fo r e Page 5. Par. 1 : I repeat my statement that the the elimination of the greenbacks was, n o t th at they d id n o t have reserve, but that they were e l a s t i c and th a t they promises o f the Government, the government in to the p o s i t i o n of banker and r e q u ir in g the Treasury to then and thus u p s e ttin g the regimen o f treasu ry a d m in istra tion and threatenin g the government c r e d i t . I t v/as d e s ir a b le to s h i f t the n o t e -is s u e fu n c t io n to a central bank, and to provide f o r the ready expansion o r c o n tra ctio n accord in g to business need. IQ w O jo g r e a o l d s o e r e n f o p u r e d r t t i n g e e m The Federal Reserve Act did intimate how the framers expected the greenbacks would be eliminated from the money o f the country, f o r it that the Secretary of the Treasury might use the government's share o f the p r o f i t s of tr^e Federal Reserve banks to pay o f f the greenbacks. p r o v i d e d The criticism of the silver certificates was quite like that of the greenbacks. The government's promise to redeem v/as in this case written on a 'iece of silver (weighing 571.25 grains pure silver) or on a piece of paper (a silver certificate having 100 $ silver reserve and circulating instead of the s ilv e r dollar). The silver dollars and certificates (taken together) were a fixed amount, coinage of the silver dollar had stopped in 1893. The Gold Standard Act of 1900 r*d required the Secretary of the Treasury to maintain all money at par one with Mother; and while no method of accomplishing this duty, it was assumed that the d would stand ready to redeem all silver dollars in gold upon demand; jji other words, that the gold reserve of the Treasury was also to support the silver currency, along with the greenbacks. This also put the Treasury in the position of banker, and it was generally regarded as desirable to substitute federal reserve notes for the silver currency, that is, shift the note issue function to the central bank* But this measure was not taken in the Federal R e s e r v e Act for the reasons, among others, cited in the paragraph. S ecretary Page 5. Par. 2 The criticism of the national bank notes was not that they did "not represent any commodity i7hatever", but that there was no .-old reserve kept against them for conversion purposes and that they were almost fixed in quantity and did not vary with the needs of business. Page 4* Par* 1* last sentence - The existence of the national bank notes, the silver coin and certificates, and the greenbacks did not in any uroper sense keep us off "an actual gold basis". That is not an element of being "on a gold basis". So long as all moneys were in law and fact redeemable in gold we were on a gold basis. To be on a gold basis requires that the monetary standard unit be defined in terms of a weight of gold, that there be free coinage of gold, that there be maintained a redemption of all moneys in gold, and that 2 old be freely exported and imported, hoarded and dehoarded, and used in the industrial arts. Page 4 . Par. 2 - Besides the slowness of "international move ment of gold" are the slow changes in gold production, in gold consumption in the arts, and in the conversion of bullion to coin and of coin to bullion. Moreover, since the amount of gold money is the resultant of so many factors, independently determined, it would be more or less fortuitous if the monetary demand for gold was answered always by an equal supply of monetary gold. These are the factors that prevent gold from answering well the requirement of being "elastic". There could be no certainty that each country would even in the long ran have the amount of gold "necessary for the purpose of carrying on the business of such country"* For instance, nevr countries were chronically cr/ing for more gold ; their adverse balances of payments made it almost impossible to maintain a gold reserve; they lived beyond their means and v/ere borrowing from the older countries, and gold left quite as soon as it arrived. Page 5. Par. 1 - I previously called attention to the fact that the scheme of regulating the volume of federal reserve notes through redis counting of commercial paper was not allowed to work long in a way untrammeled by the direct issue of federal reserve notes for gold and by the use of paper collateraled by government bonds and by the use of non—liquid (so-called) com— nercial paper. Except for the seasonal variation, there is no consistent and dependable relation between the volume of federal reserve notes and the volume of rediscounting. The volume is highly variable, but the variation is not always in the direction of business activity. Furthermore, there is nothing sure in the capacity of rediscounting to check a business boom; for as the price level rises the face value of the volume of commercial paper can be pyramided. The whole purport of iny comments on page 5 of the Frost MSS i- that it pictures the federal reserve note and rediscounting as more perfect instruments than they are or have been in actual fact. Maybe the language might *ell be tempered to avoid criticism. Page 9. Line 7. 5 - Typographical error: ’ ’ financing", not "financial1*. Page 11« line 8 from bottom and page 1 2 . — Title to first section* Should say bond-holdin^s of the federal reserve banks» rather than of the federal reserve system. The system includes the holdings of the member banks, (also on page 15). I believe it would be wise to make some pronouncement on the desirability of the member banks gradually eliminating a considerable portion of their government securities; or at least of not piling up further purchases. There are split infinitives on pages 1,7,10, and maybe others. Maybe Frost will want to eliminate these in the final draft. I have no particular criticisms of the latter part of the -IS. I still think the Council should add to their statement their position on Inter national Stabilization of the Currency, on the Gold Bullion Standard as against the Gold Coin Standard, on the present scheme of having gold certificates rather than gold the reserve of the federal reserve banks, on the matter of currency management through open-market-gold-purch3.se or through other methods advocated by monetary experimenters. A strong declaration against management, manipulation, experimenta tion, etc. might be helpful in obviating such experiences. Sincerely yours, (Signed) Ray &o P I New Haven, Connecticut, November 11, 1936 Ray Bert Yesterfield professor of Political Economy Yale University "r. Thomas M. Steele, President, The First National Bank & Trust Co*, New Haven, Conn. Dear Tom: I just reread the Frost MSS and have a few more sug gestions, some awfully minute: Page 6 line 10 Line 21 Federal reserve banks, not system Ditto Page 7 line 6 Its instead of their Page 8 line 1 The present situation is that $200,000,000 only are set aside for the purchase of ex change, gold, and government bonds. Of course, the government might jump this to $2,000,000,000 at its discretion. " ,1 line 6 Page 10 line 6 for it rather than for them This calculation does not keep in mind that reserves required are not the same as former ly. They have recently been jumped a half above what they were bet7/een 1920 and 1928. Neither the $200,000,000,000 nor the $100,000,000,000 is correct therefore. The figure $80,000,000,000 on page 12 line 10 should also be restated for same reason. page 13 line 7 from botton. system. Federal reserve banks rather than Sincerely yours, (Signed) Bay CRITICISi.i OF THE m MQBANDUM REGARDING PROPOSED ACTION BY THE FEDERAL ADVISORY COUNCIL The suggestions contained in the memorandum are subject to criticism from two angles; (a) from the angle of the general policy involved and (b) from that of the detailed suggestions embodied in it. As to the general purpose, there is some reason for suggesting the desirability of returning to an international gold standard at the present time and this matter is dealt with in the attached proposals* The ability of the United States to restore a gold standard, hov/ever, is conditioned by the willingness of other countries to take similar steps, since it is impossible to conceive of an international gold standard unless the United States, England and France, at least, should participate in it* Moreover, the restoration of such a standard requires the abolition of quotas and embargoes that now restrict inter national trade and a revision of tariff policies such as to permit increased international trade in commodities and services. Increased provision for inter national capital movements would also be a necessary prerequisite, and these conditions should be emphasised in the memorandum suggesting the international gold standard as an aim of monetary policy. Assuming that, in the light of all these facts, it was still thought desirable to recommend an international return to gold, the suggestion that the gold in the Stabilisation Fund might be eliminated from the monetary picture by an upvjard revaluation of the dollar is impossible, both theoreticalljr and as a matter of practical politics. Under any form of international gold standard the foreign exchange oarities between the different currencies must measure both the relative gold content of the monetary units and the purchasing power over commodities °£ t .ose units in their respective countries. Thus, before the war, a pound sterling - z - was worth approximately ^4.86 because the pound contained nearly five times as much gold as the dollar by weight, and also because it would purchase in England about five times as much as would the dollar in the United States- This must naturally be so since gold normally moves freely from one country to another and would naturally move to the country .vhere it would purchase most. All of this is simply another way of pointing out that any attempt at restoring the gold standard cannot succeed unless the ratio established legally among the several currencies corresponds to the purchasing power parity. While minor corrections may be necessary in one or other of the countries involved, it is reasonable to suggest that at the present time the ex change rates between the dollar, the franc and the pound correspond approximately to »urchasing power parities. With a dollar weighing l/35 of an ounce of gold, tlie pound is today worth approximately five dollars when measured by price levels in the two countries. Naturally if all the countries concerned should revalue their currencies upward, the exchange relationship would not be disturbed. Such a proposal, however, is impracticable and if the United States alone should do it, American business would be placed in the position that British business occupied in 1925. Either a decline in the American price level or a rise in foreign price levels of ^old standard countries would be necessary to restore equilibrium, and the experience of England from 1925 to 1931 suggests that equilibrium is not easily restored. Xf the three nations above mentioned should agree to return to tne gold standard with specific gold contents for their several monetary units corresponding to the existing purchasing power parities, and if there were reason to expect that such a restored gold standard 7/ould endure for some time to come, t would be possible to use the gold in the Stabilisation Fund for the purpose of r-t,_rin^ co.rie of the outstanding Government bonds. the profits from devaluation in 1928. This is what France did with - 3 - Regarding the other two proposals of the memorandum, the dis continuance of the silver purchase program would arouse no objections from any economist, although it might be politically inexpedient at present. This latter point is not of economic significance however and, in view of the fact that the acquisition of silver by the United States Treasury does nothing to strengthen the American monetary system, the immediate cessation of such purchases has very much to recommend it. The suggestion that the Federal Reserve System reduce its hold ings of Government bonds to $400,000,000 is somewhat more controversial. should balance the budget so that Administration it If the did not depend upon the capital market for immediate financing, and if it should be willing to refund some of the short term issues outstanding on the basis of somewhat higher interest rates, it is probable that the Reserve System might safely and wisely over a period of time re duce would of its present holdings by a policy of open market sales. Such a policy, however, need to be carried out very gradually in order to prevent any sudden rise interest rates in the money market. If the Administration should not be willing to adopt the fiscal policies suggested above, it is manifestly impossible for the Federal R e s e r v e Such sales letter would of the System to adopt any policy requiring substantial open market sales. weaken the market for Government bonds and, whatever may be the it is obvious that no government will allow its central bank lav/, continuously to pursue policies that run counter to its own. Minor Points of Criticism Some question can be raised regarding the definition of "sound -oney" that appears on pages 1 and 2 of the outline. While Hepburn1s definition is suitable for his purpose and for the time at which he wrote, it is not theoretically defensible, 'iore accurately, sound money would have to be defined as any type - 4 - 0f money that satisfactorily serves as a standard of value and a medium of payments, thereby facilitating the normal operations of business. ceivable It is theoretically con that an inconvertible paper currency might qualify as sound money if it -ere perfectly managed by an omniscient and omnipotent authority, and all that can be said in favor of Hepburn’ s statement is that, in the light of human weaknesses and ignorance, it is probably better that the United States should base its money uoon gold and so limit the need for management. Perhaps this is not an important criticism, because it is probable that Hepburn himself would have agreed with the above statement, but the method in which the definition is presented in the memoran dum tends to color the whole discussion. The second technical point of some considerable importance arises in connection with the suggestion on page 5 of the memorandum regarding the redis count rate. While it is a standard principle of English central banking practice that "Bank Hate is normally above Market Rate”, it must be remembered that the phrase market rate applies specifically to the rate of discount on first-class bankers' acceptances. Even in the United States the market rate on acceptances might conceivably be below the Federal Reserve buying rate (although it usually is not), xhile in England the rate charged by a commercial bank on customer loans is always at least two percent above the Bank of England rediscount rate. The difference in the tvpe of paper rediscounted by the Bank of England and the Federal Reserve Banks ~akes it impossible to make any such general suggestion as the one that Federal ‘ rserve rediscount rates should be above market rates, because in this country, where -ost of the paper presented to the Reserve Banks consists of single name customers1 ■'otee, it would be intolerable to have central bank rates above the rates charged in e7er7 part of the country. ^"▼ember 14 >CJ:ABR 1956 ALTMu^ATlVE ...Ei-aQRANDi:id CONCERNING RECOi/iivLLaTDATIONS OF POLICY Improvements in the volume of business activity and sub s ta n tia l increases in the prices of commodities and securities indicate that a business revival is well under way in the United States. merits have all th e Since these improve- earmarks of a regular cyclical expansion in business, it may be expected that business m i l continue to expand of its own momentum if nothing is done to interfere vith normal business operations in industry and commerce. Such a condition of affairs would tend to indicate that the easy money policies, adopted by the Reserve System in 1955 to encourage business revival and price-increases, have served their purpose and should now be gradually discontinued. Naturally no sudden change of policy is desirable, since sudden change might undermine the confidence of the money market, induce sharp increases in interest rates, and retard the continued expansion of business activity. The change of policy must necessarily be very gradual, but it does seem that the tine has nov: come when it is necessary to turn our attention to the problem of the methods by which the Reserve System can prevent an undue expansion of credit and a dangerous speculative boom. This problem is not easy in the light of our present circum stances and of the limited experience that we have of monetary management, but an effort must be made to find a solution since a continued expansion of business for tT7o or three years might produce a very dangerous expansion in the volume of bank ce;>osits even if no increase occurred in the stock of money in the United States 5.nc the present volume of member bank reserves. If the Reserve Board should raise member bank reserve requirements to the axirourn amount permitted by law at present, the problem would not be completely solved because substantial deposit-expansion might.still occur on the basis of szcesa reserves and the aggregate volume o f reserves would be continually increased by the silver purchases of the Treasury under the present program. Moreover such a step would make it impossible for the Board to raise reserves further without special lecal enactment (which would be difficult to obtain promptly at a time when further increases were considered necessary and desirable.) Something might be done by raising rediscount rates, but this step is rrobably undesirable at present since it would undoubtedly produce an early rise of interest rates in the market and check the revival. Nor are substantial open market sales of government bonds a practical possibility until the government has balanced the budget and refunded its short-term issues. As long as the government depends uoon the caoital market for current financing it is inconceivable that the Board should, by raising rediscount rates or substantial open market sales, follow policies calculated to make the task of financing the government more difficult. Several of these problems arise out of the peculiar characteristics cf our monetary system, and they also exist to a greater or lesser extent in several other countries. Joint international action in restoring a gold bullion standard, at least in the United States, England and France, would go a long way towards provicing us with an effective solution, and, in vie?/ of the recent international monetary agreements negotiated by the United States Treasury, it would appear that such, a step is ■possible as well as desirable at this time. If the gold standard should be restored in the three countries 'sntioned, with gold value for the dollar, franc and pound appropriate to the present ?archasing power parities betY/een these monetary units, and suitable collateral easures were taken to encourage the international movement of goods and cf capital, the problems of credit control would more closely resemble those with which we have • - experience in the past. Moreover such a policy would make possible the cessation silver purchases (for the time being at any rate) and would make it possible to iS' +-he gold in the stabilisation fund for the purpose of repaying some of the govern- aeat bonds now held by the banking system - removing two of the potentially ^nflationary factors in our monetary system. Naturally, it is assumed that if such a policy were followed, the Reserve Board (in consultation with the Bank of England and the Bank of France) 7 ,-o u lo . continue to study the methods by which credit control could be made more efficient and the general level of monetary management improved. such Moreover, if a policy were adopted now - when the danger of speculative inflation is not •urgent - it would provide an ample opportunity for adjustment to the new scheme of things and enable the Reserve System to perfect its control technique before the need for retarding the rate of deposit expansion should become urgent. To postpone action until such a time arrives may have the effect of seriously impair ing the efficiency of the Federal Reserve Board in performing the tasks that have been placed upon it. Confidential November 14, 1936 CjsLiLX. TO: Mr. Sinclair CAS SUBJECT: REVIE.7 OF Tffiii FROST ^ O R A I I D U M RELATING TO CURRENCY IN THE UNITED STATES, This statement attempts to set forth certain basic principles relating to our currency and to make definite recommendations with respect to the policy to be adopted concerning the present holdings of government securities by the Federal Reserve System, buying of silver and issuing silver certificates, and the so-called stabilization fund. The memorandum calls for a critical appraisal rather than alternative suggestions. What follows therefore is mainly in the nature of a critique based on established facts. 1. The statement starts out with Hepburn's definiti money and suggests that the Council accept this definition and thus its implica tions. Hepburn's "A HISTORY OF CURRENCY IN THE UNITED STATES0 was first published in 1903, then revised in 1915 and in 1924. No later edition has appeared, though one is planned to be issued in December this year. The definition, therefore, was formulated some years ago when conditions were different from what they are now. Biit this fact does not necessarily impair the validity of basic principles, though Hepbum himself states in the second paragraph to the one quoted in the memorandum that: "The test of sound money varies with different periods, and is determined by var/ing conditions. The term has, however, a general significance easily under stood, is concise, cogent and seems to have found a permanent place in our economic literature.0 Apparently this "general significance" varies according to prevailing conditions over long periods. The implication is that the static definition is aot to be adhered to literally and that is precisely what the memorandum does. Moreover, it is not true that all students of money today accept Hepburn's definition of sound money, largely because of the difficulty of knowing the meaning of the •jhra.se unless it may be taken literally in connection with the testing of coins which, 7711611 dropped, ring true or false. Then, too, fundamental conditions have changed very greatly since the definition v»as formulated. Probably the best test of sound currency is when the people believe in it and accept it in their ordinary transactions and when that currency lias a standard of value which makes it also acceptable in international payments. The definition gives a clear implication that sound money is ,!unouestionably redeemable in" gold. It also refers to the gold coin standard such as existed in this country until a few years ago. to the standard we now have. Obviously, it is not applicable Does it then mean that the Council virould suggest the refrora to the gold coin standard, making our currency convertible into gold coin on demand? For that is the meaning implicit in Hepburn's definition of sound money. If it does, the statement should say so, otherwise this definition is beside the loint and should not be a basis for further development of the case. 2. Reference is made to certain basic principles obser connection with the legislation creating the Federal Reserve System in 1913. In general, it should be remembered that the original Act was the result of many compromises, attempting to adopt the best banking system possible for this country. It 77as also intended to be a living and working organism. YJhile it may not have set all the exaggerated expectations of its sponsors, it lias been adapted to chang ing conditions either through administrative measures or through legislation, to Tit: changes in reserve requirements, real estate loans, discounts and advances, discount rates of bank gone a credit. Ion;~ and other changes relating to measures of control and administration In way from its efforts to meet changing conditions the reserve system has both the conditions and the thoughts prevailing at the time alien i t was founded. 3 - The historic argument thus is hardly convincing. If s0nie hold that we have departed too far from the original intentions, this is beside the point in any consideration of conditions as they now exist. 5. An emphasis is placed on the fact that the Treasur be able to redeem in gold at all times a large portion of currency so that it w ould be possible to maintain full confidence in such fiduciary elements as are implicit in the subsidiary or representative money. But it should be noted that by far the greater part of our currency supply at present rests on the gold base. The United States notes amounting to about $540 millions have back of them a gold reserve fund of ?p.56 millions established under the Gold Reserve Act of 1900. Federal reserve notes in actual circulation as of November 10 amounted to over $4.1 billions and the collateral held as security for these notes consisted of: 54,396 millions in gold certificates, §5 millions eligible paper and $93 millions United States government securities, making a total of 04,494 millions* Silver certificates, Federal reserve bank notes, and national bank notes, of which about ^1560 millions were outside of the Treasury, nave no direct gold base. But it must be remembered that all forms of money are legal tender and must be kept at a parity in relation to gold. In pointing out the presence of such elasticity on the side of the reduction in the currency supply, the statement injects a controversial feature by saying "provided, of course, that the rediscount rate is above the mar ket rate for funds”. This rule of thumb is of British origin, often resorted to 'Without realizing the essential differences between the money market structures in England and this country. For example, the British banks make advances to tjr.eir customers largely through overdrafts and do not require promissory notes as is done in this country. A British bank does not borrow directly from the Bank -n^’ and but adjusts its position through bankers1 end Treasury bills as well its loans to bill brokers. TFnenever necessary these brokers sell bills to the - 4 - gank o f England a t the d is c o u n t r a t e o r borrow from the Bank on b i l l s . The r a t e s at which the B r i t i s h banks len d t o t h e i r customers are u s u a lly somewhat above the Sank of England r a t e . The discount rate in the Un ited States applies to promissory note s T.h'.ch member banks present w i t h their endorsement to the reserve banks, or to the menber banks1 own notes secured by their customers' notes or by government o bliga tions. "If a member bank lends its commercial customer on his note at 5 per cent, tie value of this note with a b a n k endorsement ma y be represented by a rate no t f a r from 5i to 4 per cent. If at that time the Federal reserve bank rate is 4 pe r cent it is really equal to or above the rate 7/hich represents the paper's true value." These explanations are taken from the latest study by W. R. Eurgess of the F ed e r a l F.eserve FknV of New York (The Reserve Banks and the Money Market). The principle back of this controversial rule is that banks should not be able to make money by borrowing at reserve banks and that by being above the market rate the discount rate should be in the nature of a penalty rate. This is a subject that requires much closer study than the mere qualifying proviso used in the nemorandum. The truth of the natter is that by virtue of the fact that cash on hyid does not count as reserve in the hands of member banks there] is always a strong v- tendency for currency to return to the reserve banks, thereby avoiding redundancy. Taenever member banks have large excess reserves this may be less pronounced than at a ti” e Then they are forced to borrow in order to maintain their required balances. If banks crust borrow, then naturally they will return currency not needed to the reserve banks in order to pay off their indebtedness, since by doing this they save interest charges. This should hold true whether or not the Federal reserve discount rate is above the rate charged customers. Regardless of the backing of the currency, there fore, it appears that elasticity has been imparted to the whole currency structure ^ ?j° far ae elasticity may be construed to mean responsiveness of money to the needs - of trade and industry. 5 - There is no question as to the ability of the reserve banks to meet the current demand for money needed for:such important items as payrolls and retail trade. In any discussion of our currency problems it should not be forgotten that probably about nine-tenths of all current payments for goods and services are sade by the use of checks drawn against deposits at banks. a deposit credit is utilized for domestic exchange purposes. A check is a means by which In practice, therefore, deposit credits perform much larger functions as media of exchange than do actual currencies, subsidiary coins and representative notes. 4. An attempt is made to build up an argument against t holdings of government securities by the Federal Reserve System. Generally speaking, it- ~oes •without saying that it would be much better if the distribution of government debt could be widely made among our population but apparently this has not been the case, as it is in other countries. This is probably due in part to the adventurous temperament of the American people to take risks and either lose or realize more than the yield from government securities. The largest concentration in holdings of government securities in this country thus is in financial institutions and large estates. Maybe this is a question of long education, built up gradually on the basis cf enduring confidence in our credit system generally and in government credit particu larly. Specifically, the memorandum states that the purchases cf government obligations by the Federal reserve banks have resulted either in the issuance equivalent amount of Federal reserve notes or in reserve balances. of an The first part of this statement is not true, since the Federal reserve notes at present are secured practically 100 per cent by gold certificates. The second part is true but is not necessarily alarming, particularly since holdings are at the discretion of the Federal Open Market Co ritteej in fact it may be quite desirable to hold the present amount as instrument to be used in case of any undue credit expansion. - 6 - It must be recalled that after a very sharp increase in purchases 0f governments by the Federal reserve banks in the early part of 1932 and the latter cart of 1935 there lias been virtually no change in the volume of these securities held by the reserve banks* It must also be remembered that so far there have been no definite convincing signs that bank credit is being used to any large extent in either the security or commodity markets. If the reserve banks should sell |2 billions of their holdings of rcvemment securities the effect on the market for these securities unquestionably O would be drastic; even a gradual reduction might easily result in an extreme con struction of the policy by those who watch the markets. Unless the Treasury would counteract such a step, as it readily can, the effect on the capital account of all banks at present might be exceedingly serious. Another effect, of course, would be a reluctance to buy governments at present yields, so that higher rates of interest -,7 ould have to be offered. While Treasury refinancing within the next year or so appears to be relatively small, about |8.7 billions of Treasury notes will mature between 1937 and 1941. This is an important factor to be considered from the stand point of both banking and Treasury financing. Close cooperation betv/een the two is essential. 5* Little or nothing favorable could be said by any thoughtful student with respect to our position as to silver* Largely under the pressure of special interests we have got ourselves into insuperable difficulties and now it is probably a question of how to get out of them legally and gracefully. Use of the method In the first rooosed in the memorandum at this time would be questionable. place it would reouire legislative action to modify the present law. To retire a large -art of the silver certificates and attempt to sell silver in the world markets would seen to be doubtful expedients at ^resent. offered? Can the world absorb the silver so hat would be the effect on prices, exchanges and trade? It would lead to even greater disorganization in the silver markets of the world than it did at the when we v/ere buying silver* 7 - It would certainly affect the silver interest in our v.m country and this would produce another political howl. In effect it would mean jump- jrg out of the frying pan into the fire and the fire would indeed be white hot. The best way out for the time being probably would be to make our silver ^ro^rsun passive, if this is possible under the law. Certainly it would be advisable to resist any attempt to issue notes against seigniorage. The content of the silver dollar also cay be increased, thereby changing the monetary value of silver as the President car do under the present statute. But whatever is done the foremost question should be: is now the time to do it without embarrassing the administration and bringing adverse criticism from the silver bloc? Would not time help to expose the folly of the existing measures and eventually help do something about meeting this problem rationally? 6. The position taken in the memorandum with respect to th tion fund seems peculiar to say the least, particularly in view of the latest monetary developments. In its remarkable simplicity, singularly unperturbed by the monetary events that are now taking place, the statement takes no cognizance whatever of the recent cooperative agreement entered into by the United States, France and Great Britain as well as several other commercial nations to bring order out of chaos in world exchanges and trade. All these nations have established stabilization funds for the purpose of moderat ing exchange fluctuations and ultimately attaining some workable level of currency relation* s'.'ips so that trade and payments can once more become sanely operative. After a most troublesome period, the leading industrial nations show a 3trong desire to relax and gradually remove the trade-choking folly of controls, restrict-'.ns, tariffs, quotas and other trade impediments. Surely this would be to our interest. - could then sell more freely such of our surpluses as cotton, automobiles, diverse ^rrofactures, and many farm and animal products; we could also buy more freely such ®EBentials as manganese, rubber, tin, silk, tea and coffee. What the world needs today *8 stability and until the present undertaking shows definite signs of success it is - 8 - necessary that we retain the means provided by the stabilization fund for safeguard ing the posit on of our currency in the international markets. Is it the intention of the memorandum to disregard the facts of this trend, assume a fatalistic attitude, or expose ourselves to certain hazards that may not be foreseen at the moment? Complete monetization of our large gold stock in one way or another say be possible, though not probable, and might be considered as undesirable. is the presence of foreign capital in this country to be ignored? But One of these days night not the political and military situation abroad change suddenly and might not the owners of this capital become shaky in their faith with respect to our own situation and to our dollar? Such tilings happened not so long ago. What effect Trould it have on our excess reserves if we had to part with a considerable portion of our gold? Those in authority already are conferring with the Executive on this very subject. The fact that the Secretary of the Treasury could stop shipment of gold from this country would be of small consolation; rather it would be an admission of monetary short-sightedness and consequent inability to cope with the problem. Practical wisdom and financial statesmanship would seem to indicate that, if anything, the oresent stabilization fund should be continued beyond January next, at least until world stabilization becomes more assured than it is at present. Certainly our monetary position would be made doubly vulnerable if we revalued the dollar upY/ard, as the memorandum proposes to do, in order to absorb the two billion dollars gold or the so-called "gold profit". By undoing the former act of Congress at this time only confusion and great harm can be the result. rjvei: such conservative monetary economists as Professor Kemmerer deny the advisa bility of going back to the former weight of the gold dollar. One wrong cannot right another, any more than misbehavior in one nursery means a like misbehavior in another nursery. ??uch as some may like to return to the old gold coin standard, one cannot soberly disregard the stark realities of the present situation. No pious *ish or spectacular oublic statement can remedy it without producing immeasurable «..uage interna’ ly and externally. No degree of assurance that "this statement is not made fo r the purpose of* eith er condemning or praising past actions . . . " i s a convincing and e f f e c t i v e safeguard against self-exposure and the ju s t ifi e d criticism that would in evitably fo llo w should the memorandum in i t s present form be given out to the country. 7. In considering the future outlook, the memorandum rave misgivings with respect to the immutability o f human nature and the w illin g ness of bankers and business men to expand th e ir c re d it operations to the le g a l limits when confidence returns. In support o f th is statement, the memorandum shows an increase in t o t a l deposits (other than interbank deposits) o f 35 per cent from June 1933 to June 1936. This comparision tends to exaggerate th is expansion at least to the extent that the low point reached by deposits in the middle o f 1953 orobably was due in part to the f a c t that many banks at that time were s t i l l on the restricted basis and were lice n se d a fte r that date. But i t cannot be denied that deposits since 1S33 have increased very greatly, r e fle c tin g in large part emergency expenditures, financed by the issue o f new government s e cu ritie s which were acquired in substantial amount by the banks. Two things must be remembered, however; the use of bank c r e d it by business and the stock market so fa r has not been la rge, as shovm. I57 loans o f a l l types; and the continuous improvement in business is re su lt ing in larger incomes to corporations, individuals and consequently to the govern ment, which is to say that r e l i e f expenditures are declinin g, employment i s in creasing and the prospects f o r cu rta ilin g government expenditures may become more hopeful. The memorandum points out that in other years, from 1920 to 1928, the ratio o f deposits to reserves fluctuated within a range between 20 to 1 and 23.5 to 1 . From this the ,memorandum assumes that i t would be reasonable to expect a —-tio of deposits o f a l l banks to member bank reserves o f 20 to 1. Adding to the total of reserves nov; held, a possible $ l j b illio n s through additional issues o f e-*-lver currency and % Z billions through the use of the stabilization fund, i t - 10 arrives at $10 b i l l i o n s o f reserves; applying the 20 to 1 ratio this would indicate p o s s ib le deposit expansion to $200 b i l l i o n s . Of course 20 to 1 was based on reserve requirements as they stood between 1920 and 1928. h a lf Since then an increase o f one- in requirements has been made and the memorandum admits that i f the f u l l powers 0f the Board o f Governors were used, deposits might expand to §100 b i l l i o n s only. This figure is much l e s s s t a r t lin g than the memorandum apparently intends to convey in first arriving at $ 2 0 0 b i l l i o n s . This portion o f the argument c le a r ly implies that at present we are face to face with a d e f in it e p o s s i b i l i t y o f tremendous cred it in fla t io n and that there is no possible method o f c o n t r o llin g i t under present conditions. This asser tion *ould be quite serious i f i t could be borne out by established f a c t s , including s o z e heedless attitu de o f the a u th o ritie s toward th is problem. There i s at present no clear evidence o f any undue use o f bank credit in speculative channels or in trade and industry f o r th e ir legitimate requirements, as has been indicated b e fo r e . But i s there anything necessarily harmful in cred it expansion as a r e su lt o f c y c l i c a l improvement in business which seems to be now in progress? I t should be remembered that the volume o f accumulated shortages in durable and seni-durable goods during the depression appears to be s t i l l very large indeed. Neither has the obsolescence o f consumers* goods been as y e t f u l l y met, disregarding for the moment the new wants o f our growing population. |o before reaching anything li k e a saturation point. We have thus a long way to True, the time may come when credit begins to pyramid upon i t s e l f and cease to fo s t e r actual business expansion along healthy lin e s . in tine to This o f course must be watched and controllin g means applied revent the downward s p ir a l. I t is also true that our c re d it base is un- 'jrecedently large, even i f allowance i s made fo r possible foreign withdrawals which would involve a reduction in our monetary gold stock. I t i s not to be forgotten , however, that very d e fin ite e ffo r t s already have been, made to check any untoward developments with respect to injurious - 11 credit expansion. I t w i l l be r e c a lle d that as early as January this year the Federal j^serve Board raised the minimum margin requirements on loans by brokers. r applying to banks, also went in to e f f e c t in the f i r s t half o f this year. Regulation Another evidence is afforded by the a c t io n o f the Treasury when i t shifted a portion o f i t s balances from the commercial banks to the reserve banks, resulting in the reduction of excess reserves. The l a t e s t p roo f o f steps taken in the same d irection i s that of the Board o f Governors in r a is in g the le g a l reserve requirement o f member banks dy 50 per cent, e f f e c t iv e August 15. *1,470 millions. This a ct reduced excess reserves by about I t would thus seem that the authorities are aware o f the potential dangers and are prepared to a c t a t the time deemed proper. Neither must i t be forgotten that the Executive consistently refused to use the in flation ary powers granted him under the s o -ca lle d Thomas amendment, that he vetoed the Patman soldiers* bonus b i l l c a llin g f o r the issue o f §2 b i lli o n s in Greenbacks'1, and that he likew ise fought the Frazier-Lemke Farm Mortgage b i l l c a llin g for the retirement o f the mortgage debt o f farmers by an issuance o f f i a t currency. attitude was s ig n ific a n t then and most li k e l y continues to be so no?.r. Would i t therefore be wise to create an aggravating situation pre cisely at th is time, .just before the Congress meets? Prudent statesmanship does not necessarily mean a s a c r ific e o f principles; i t may mean a speedier solu tion o f trying problems through wise coimsel and cooperative e f f o r t s . In making the t h r e e -fo ld recommendations relatin g to the government :ond holdings by the Reserve System, s ilv e r and s ta b iliz a t io n fund, the memorandum makes ' considerable point o f the f a c t that the action should be gradual so as not to disturb the existing conditions folio-/ r e d tore than necessary. under any circumstances. Naturally this procedure would have to The objectionable feature o f giving out a s ta te - ;‘ ^t 3uc:i as contained in the memorandum is the very suggestion o f what is proposed to rj* done. The question is: what can be accomplished at this time by taking the sug- gestea steps at a l l ? 12 - Would the a c tio n o f the kind proposed be timely or pre mature? The s o le purpose o f this critiq u e i s to give an honest appraisal o f the F rost memorandum with utmost frankness. Lack o f time pre— Vcats its revision which would undoubtedly resu lt in greater p recision and comprehensiveness than i t now has*