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M I N U T E S OF MEETING
of the
FEDERAL ADVISORY COUNCIL
October 8 'io, 1939

MINUTES OF M E E TIN G OF THE FEDERAL ADVISORY COUNCIL
October 8, 1939
The third statutory meeting of the Federal Advisory Council for 1939 was convened
in Room 836 of the Mayflower Hotel, Washington, D. C., on Sunday, October 8,1939, at
10:40 A.M., the Vice President, Mr. Loeb, in the absence of the President, in the chair.
Present :
Mr. Thomas M . Steele
Mr. Leon Fraser
Mr. Howard A. Loeb
Mr. T. J. Davis
Mr. Charles E. Rieman
(Alternate for Mr. Robert M. Hanes)
Mr. Edward Ball
Mr. Edward E. Brown
Mr. Sidney Maestre
(Alternate for Mr. Walter W. Smith)
Mr. John Crosby
Mr. John Evans
Mr. R. Ellison Harding
Mr. Paul S. Dick
Mr. Walter Lichtenstein

District
District
District
District
District

No.
No.
No.
No.
No.

1
2
3
4
5

District No. 6
District No. 7
District No. 8
District No.
District No.
District No.
District No.
Secretary

9
10
11
12

The Vice President announced that Mr. Walter W. Smith was ill and, therefore,
unable to attend the meeting. It was unanimously voted to instruct the Secretary to send
a telegram to Mr. Smith, expressing the regret of the members of the Council at his absence
and wishing him a speedy recovery, with the hope that he would be able to be present at
the next meeting of the Council.
The Secretary reported that, in accordance with the request of the Board of Governors
of the Federal Reserve System, information had been given the Board, as far as such was
possible, regarding complaints of undue centralization in the System in so far as such
appeared in the statistics collected by a committee of which Mr. Lewis B. Williams had
been chairman.
It was decided to discuss the “ easy money” policy in accordance with the request
transmitted in the letter, dated August 18,1939, from the Secretary of the Board of Gover­
nors of the Federal Reserve System to the Secretary of the Council. The feeling was
expressed by most of the members of the Council that it would be undesirable to present
a formal recommendation, but that it might be well to draw up a memorandum to form
the basis of a discussion with the Board of Governors at the joint conference of the Board
and the Council. Mr. Brown was asked to prepare such a memorandum.
A discussion took place regarding the proposed investigation of the banking system
as directed in an act introduced by Senator Wagner (S. R. 125). It was decided to invite
Mr. D. J. Needham, General Counsel of the American Bankers Association, to discuss the
matter. However, it was found that Mr. Needham was out of the city and not expected
to return for several days. As there was a general feeling that nothing would be done in
regard to this investigation of the banking system prior to the next meeting of the Council,
it was decided to postpone consideration of this problem for the present.




1

There was some discussion in regard to the ruling of the National Labor Relations
Board in favor of the C. I. O. in the Bank of America case. Mr. Steele pointed out that
in view of the recent decisions of the Supreme Court of the United States, it was, in his
opinion, very doubtful whether any action by banks seeking to have the ruling changed
would be advisable at this time.
No action wras taken in regard to the bill passed by the Senate which would exempt
inter-bank deposits from being subject to payments to the Federal Deposit Insurance
Corporation.
The members of the Council lunched together in Room 859 from 12:30 P.M. to
2:15 P.M. and then reconvened in Room 836.
Discussion took place regarding the various proposed amendments to the Federal
Home Loan Bank Act, as approved June 22,1932. Mr. Dick pointed out that branches of
these banks would be in competition with all classes of savings banks.
The Secretary read a memorandum submitted by Mr. Loeb, which was made a part
of the records of this meeting.
It was finally agreed that the Chair appoint a committee to report back regarding
the amendments to the Federal Home Loan Bank Act at the next meeting of the Council.
The Chair appointed the following committee: Messrs. Dick, Chairman, Steele, and Hanes.
Mr. Brown submitted a memorandum on “ easy money” policy, which was discussed
at length. It was decided to request Messrs. Brown, Fraser, and Evans to re-draft the
memorandum and incorporate in it a preamble. It was, however, unanimously agreed that
the memorandum expressed the views of the members of the Council.
The meeting adjourned at 4:00 P. M .




WALTER LICHTENSTEIN,
Secretary.

2

MINUTES OF M E E TIN G OF THE FEDERAL ADVISORY COUNCIL
October 9, 1939
At 10:05 A. M. the Federal Advisory Council convened in the Board Room in the
Federal Reserve Building, Washington, D. C., the Vice President, Mr. Loeb, in the Chair.
Present: Mr. Howard A. Loeb, Vice President; Messrs. T. M. Steele, Leon Fraser,
T. J. Davis, C. E. Rieman, Edward Ball, E. E. Brown, Sidney Maestre, John Crosby, John
Evans, R. E. Harding, P. S. Dick, and Walter Lichtenstein, Secretary.
At the beginning of the meeting, Mr. Rieman was not present, but joined the meet­
ing at 10:25 A. M.
The Secretary of the Council reported that, in accordance with instructions, he had
sent a telegram to Mr. Smith.
The Secretary read a draft on “ easy money” policy submitted by Messrs. Brown,
Fraser, and Evans. A very exhaustive discussion took place regarding the memorandum
submitted and many changes in detail were suggested.
At 11:10 A.M . Dr. E. A. Goldenweiser, Director, Division of Research and Statistics,
appeared before the Council and discussed the general financial and business situation.
Dr. Goldenweiser left at 12:35 P. M. and the Council adjourned at 1:00 P. M. for
luncheon with Chairman Marriner S. Eccles.
The meeting reconvened at 3:40 P. M.
Discussion continued regarding the memorandum embodying the views of the Coun­
cil on “ easy money” policy, and it was unanimously agreed to present the following at the
joint conference of the Federal Advisory Council and the Board of Governors of the
Federal Reserve System as representing the unanimous opinion of the members of the
Council:
“ In connection with further consideration of the ‘easy money’ policy, as suggested
in the letter of the Secretary of the Board of Governors of the Federal Reserve System to
the Secretary of the Federal Advisory Council, dated August 18,1939, the Federal Advis­
ory Council was led to examine the recent changes in the yields of corporate and Govern­
ment bonds. As to the general topic of extreme easy money, the Council reaffirms the
views expressed in its recommendation to the Board of Governors, dated June 6,1939.
“ While the Council fully recognizes the need in a grave emergency, such as that
recently experienced, of taking steps designed to preserve an orderly market in Govern­
ment securities, it also believes that the market price of Government bonds should be
allowed to find its natural level, free of official intervention, as rapidly as possible con­
sistent with an orderly market.
“ The operations of the Open Market Committee, acting for the Federal Reserve
banks, in maintaining an orderly natural market (as distinguished from a pegged market)
should not be influenced by its judgment as to what the proper price level should be, but
that level should be the result of general operations of willing normal buyers and sellers.
Neither should it be influenced by any considerations of maintaining or extending the
former policy of extremely easy money.




3

“ The Council believes that any policy of maintaining an orderly natural market in
Government securities makes advisable the sale of the bonds and notes bought in the
process of maintaining an orderly market as and when the free market will absorb them,
and that these bonds and notes should not be withheld with a view to forcing the price
of bonds back toward pre-September prices.”
The meeting adjourned at 4:10 P. M.




WALTER LICHTENSTEIN,
Secretary.

4

MINUTES OF JOIN T CONFERENCE OF THE FEDERAL ADVISORY COUNCIL
AND THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
October 10, 1939
At 10:40 A. M. a joint conference of the Federal Advisory Council and the Board of
Governors of the Federal Reserve System was held in the Board Room of the Federal
Reserve 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 John K.
McKee, Chester C. Davis, and Ernest G. Draper; also Messrs. Lawrence Clayton, Assist­
ant to the Chairman of the Board of Governors;Elliott Thurston, Special Assistant to the
Chairman; Chester Morrill, Secretary of the Board of Governors; L. P. Bethea, Assistant
Secretary of the Board of Governors; Walter Wyatt, General Counsel for the Board of
Governors; J. P. Dreibelbis, Assistant General Counsel of the Board of Governors; L. P.
Paulger, Chief, Division of Examinations; R. F. Leonard, Assistant Chief, Division of
Examinations; Dr. E. A. Goldenweiser, Director, Division of Research and Statistics; E. L.
Smead, Chief of Division of Bank Operations, and C. E. Parry, Chief of the Division of
Security Loans of the Board of Governors.
Present: Members of the Federal Advisory Council:
Mr. Howard A. Loeb, Vice President; Messrs. T. M. Steele, Leon Fraser, T. J. Davis,
C. E. Rieman, Edward Ball, E. E. Brown, Sidney Maestre, John Crosby, John Evans,
R. E. Harding, P. S. Dick, and Walter Lichtenstein, Secretary.
The Secretary of the Council read the statement on “ easy money” policy appearing
in the minutes of the meeting of October 9, 1939. A long discussion took place between
the members of the Council and the members of the Board. The members of the Council
presented some criticisms as to certain details in respect to the methods employed in
carrying out the recent decisions of the Open Market Committee, but stated that they
were in accord with the general policy adopted by the Open Market Committee during
the recent emergency brought on by the outbreak of the European war. The principal
criticism on the part of members of the Council was in respect to the requirement that for
a time names of proposed sellers of Government bonds, if these were offered directly to the
Federal Reserve banks, had to be revealed by the agent of the seller. Members of the
Council felt that this might prevent a certain amount of entirely justifiable selling, and in
so far as this was true, interfered with the establishment of an orderly natural market.
Members of the Board of Governors stated that the memorandum of the Council was
not critical and also declared that they were entirely satisfied with the answers made by
individual members of the Council to various questions raised by members of the Board.
In concluding, Chairman Eccles made a lengthy statement, explaining his position and
what his policy in the past had been.
The meeting adjourned at 12:30 P. M .




WALTER LICHTENSTEIN,
Secretary.

5

MINUTES OF M E E TIN G OF THE FEDERAL ADVISORY COUNCIL
October 10, 1939
At 12:35 P. M . the Federal Advisory Council reconvened in the Board Room of the
Federal Reserve Building, Washington, D. C., the Vice President, Mr. Loeb, in the Chair.
Present: Mr. Howard A. Loeb, Vice President; Messrs. T. M. Steele, Leon Fraser,
T. J. Davis, C. E. Rieman, Edward Ball, E. E. Brown, Sidney Maestre, John Crosby, John
Evans, R. E. Harding, and P. S. Dick.
It was unanimously voted to adopt the memorandum on “ easy money” policy as
expressing the views of the members of the Council and to instruct the Secretary to place
the statement upon the minutes of the Council. It was also unanimously voted to request
each member of the Council to give a copy of this statement to his respective local Federal
Reserve bank.
The meeting adjourned at 12:50 P. M.




WALTER LICHTENSTEIN,
Secretary.

6

COPY

October 2, 1939

COMMENTS ON THE AMENDMENTS TO THE
FEDERAL HOME LOAN BANK ACT. HOME OWNERS' LOAN ACT OF 1933
AND THE NATIONAL HOUSING ACT

Proposed in the 1st Session of the Seventy-sixth Congress

I t seems e n t ir e ly w ith in the scope o f the Federal Advisory
Council to review these amendments and to make su ita b le representations

to ihe Board o f Governors o f the Federal Reserve System as the contents
of the amendments are r e la t e d to nthe general a f f a i r s o f the reserve
banking system” .

The proposed broadening o f c re d it powers o f the federal

mortgage-lending agencies would a f f e c t the reserve conditions of the re­
serve banks and the banking str u c tu r e as a whole.

The proposed amendments

are o b jectio n ab le on se v e r a l grounds.
The Federal Home Loan Bank A c t, as approved June 22, 1932, was
adopted primarily to fu r n ish a more f l e x i b l e means by which various building,
savings and loan a s s o c ia t io n s , and other in s t it u t io n s engaged in making
long term home-mortgage loan s might fu r n ish c r e d it fo r home building,
^

thereby encourage home ownership.

I t was to provide a source o f reserve

credit for these agencies in p eriod s o f f in a n c ia l emergency.

The twelve

Hone Loan banks created under t h i s Act were to make advances on the se flirtty of home

mortgages to t h e ir members.

For that reason these banks

permitted to accept as c o l l a t e r a l mortgages on properties designed



-2 -

f or r e s i d e n t i a l use fo r no more than

fou r fa m ilie s .

The proposed amend­

ments would remove th is lim it a t i o n , so th at an advance may be made on a
mortgage up to $ 1 0 0 ,0 0 0 ,

and th e m aturity o f such a mortgage would be

extended from twenty to tw e n ty -fiv e years*

As the proposed amendments would permit Federal Home Loan banks
to make advances on c o l l a t e r a l secured by any f i r s t mortgage, they would
place the members o f the Federal Home Loan banks - building and loan as­
sociations, fed era l savings and loan a s s o c ia tio n s , e t c , - in direct com­
petition with banks, insurance companies, and other in stitu tio n s making
first mortgage loans on business as w e ll as home p ro p erties.

This broaden­

ing of the powers o f savings and loan a sso c ia tio n s in e f fe c t would establish
another banking system o u tsid e o f the present supervision and control.
Federal Home Loan banks are authorized to issu e bonds and deben­
tures.

The proposed amendments would a ls o authorize the Secretary of the

Treasury to buy these bonds and debentures and in turn issu e Treasury bonds
to raise the necessary funds with which to pay fo r such ob lig a tio n s.
Treasury bonds so issu ed are to be tr e a te d as public debt.

The

The significance

of this provision i s fu r th e r emphasized by the fa c t that any impairment of
capital of a Federal Home Loan Bank - a minimum o f such c a p ita l being
$5,000,000 fo r each bank subscribed t y the Secretary o f the Treasury - would
result in a lo s s to the Treasury.
As each Federal Home Loan Bank has powers to accept deposits from
its members, to in v est in o b lig a tio n s o f the United S ta te s, and to borrow
funds, i t is not u n lik e ly th a t the twelve Federal Home Loan banks may a c Suirs government s e c u r itie s and then use them as c o lla te r a l fo r borrowing
from the Reserve banks.



While the Reserve banks under the present laws

-3 and regulations presumably enjoy a considerable la titu d e o f discretion in
accepting or r e je c tin g such o b lig a tio n s , i t

is

conceivable that a stringent

situ ation might a r ise wherein such a d isc re tio n would become purely academic•

By means o f in te r p r e ta tio n s , r e g u la tio n s, or enactment of additional laws,
the Federal Reserve banks may be forced to make advances, secured by govern­
ment ob liga tio n s, to the Federal Home Loan banks, as w ell as other govern­

mental credit agencies having powers to in v est and to borrow.

The proposed

amendments co n stitu te a step in th at d irectio n and are therefore

dangerous

to the reserve conditions o f the banking system.
The Home Owners1 Loan Act o f 1933 was adopted to provide r e l i e f
with respect to home mortgage indebtedness, to finance home mortgages, to
extend r e lie f to the owners o f homes occupied by them, and who are unable
to amortize th e ir debt elsew here.

The purpose o f th is Act and that o f the

Home Loan Bank Act was to encourage people to save enough to make a down
payment on a home and to a s s i s t those in d is t r e s s , and i t was never intended
that savings and loan a sso c ia tio n s would do a savings bonk business.

The

proposed amendments broadening c r e d it powers o f such associations would
change the o r ig in a l in te n tio n and tend to aggravate further the existin g
relationship between the a sso c ia tio n s and the banking and insurance systems
of providing mortgage c r e d it .
Under the N ational Housing A c t, there was created a Federal Savings
and Loan Insurance Corporation, a t i t l e which i s proposed to be changed to
Federal Savings Insurance Corporation.
15,000 for each ’’ insured account” .

The insurance coverage i s placed at

I t i s estimated that the average amount

invested by in d ivid uals in the shares o f Federal Savings and Loan Associations
does not exceed $700.
^

Every e f f o r t i s being made to extend Federal Savings

Loan Associations and place them in competition with savings banks,




-,4-

cooperative

banks, mutual savings bank, state chartered building and loan

a sso c ia tio n s,

and other th rift institutions.

The proposed as well as

previous amendments apparently give no regard to the safeguard and limitations
to

tfhich other existing institutions must subscribe.
Federal Savings and Loan associations, newly established and those

converted from state associations, have been charged with unfair
solicitation of business.
misrepresentation.

These charges are based on direct or veiled

For example, the word "federal" has been used freely,

suggesting that such associations are protected t y the government; the word

"guarantee” has been stretched to mean an assurance of dividend or interest
payments; and that a ll funds invested in shares were "fu lly insured" and
"prompt cash settlement" would be made in the case of failure.

While these

practices have been o ffic ia lly recognized and disapproved, it is difficult
to control those who are in the field working in the interest of these
associations.
In short, Federal Savings and Loan Associations have been placed
in and they have been prone to usurp a privileged competitive position
largely because of advantages through tax exemption, investment policies,
irregular examinations, and other features which may not be practiced ty
the

established th rift organizations.

shares at the rate of U per cent.
because

They are able to pay interest on

This is obviously unfair to savings banks

of limitations, restrictions and requirements with respect to the

maintenance

of reserves, limited investment field s, nontax exemption, as

veil as other minor restrictions which limit their earnings, so that these
banks

are unable to

pay

more than

2

per cent interest on savings accounts.

It seems to be a clear case of private institutions, which have provided one



- 5-

of the most Important sources fo r

c a p ita l formation, and are now being

pushed to the wal l by the a sso c ia tio n s which are in e ffe c t encouraged
and subsidized by the government regard less o f p ossible lo s s to the tax
payers in the fu tu r e .

The proposed extension of th eir powers i s an

unjustifiable attempt to make fu rth er inroads into the existin g cred it
structure by governmental

agencies and th e ir s k i l l f u l l y contrived p o lic ie s

and methods#
The proposed amendments would fo s te r a further centralization of
this type o f

c re d it fin an cin g under the supervision o f a federal bureau

responsible only to the President*

Together with the existin g powers over

credit, these amendments would tend to undermine the private in stitu tio n s
unless such in s titu tio n s chose to abandon th e ir present charters or convert
their business to Federal Savings and Loan A sso cia tio n s.

This would mean a

further exposure to the co n tro l and domination o f fed era l bureaus.
Viewed from the p oin t o f money, c r e d it, and banking, the proposed
amendments are h ig h ly o b jec tio n a b le

because they tend to set up a nation­

wide branch banking system o f a p ecu lia r s o r t , to monetize mortgages o f
long m aturities, and to c e n tr a liz e the management o f cred it under a
p o litic a lly -c o n stitu ted fe d e ra l a u th o r ity .

I t i s a further evidence of

determined e ffo r t s to s o c ia liz e our banking and c re d it system - a most
decisive step in breaking down our democratic processes*




C O P Y

gxc.srpt

'a a letter fron* Mr. £. U. Docker, August 22, 1939.

"In an effort to amswer the questions pro poundad in your la tte r
of July 18, I have re-exaainad the Material which furnished the bfcsis
for the Federal Advisory Council*s report to the Federal Reserve Board
oo the question of increasing the System's services to saember oanks*
Cotnwents advocating ajor© authority for the District bank in

a* aining »e»b<s s appear in letters fro* two State banks and *wo
Sati nal bonks in the Second D i s t r i c t .
One n ation al bsoik in the Second D is tr ic t expresses preference
for the Comptroller1& examination, &nr one State bank in the Third Dis­
trict advocates an examination b y S ta te a u th o ritie s, of su ffic ie n t scope
to satisfy *11 of the other supervising bodies. The rest of the cosrents
oo examination tcvocate uniform ity, without expressing preference
the agency which should asks the examination.
b e

t o

On the question of the c e n tra lisa tio n o f authority in fa hington, the acntiscint of the banker*
is against ouch centrali­
sation*
There follows a tab u lation of the comments by D is tr ic ts , broken
down into State end Bat tonal bants wherever possible*
i^.axnst G c n tr ^ lj:^ ■j. n
S tate

D istrict 2

3
4
5
6
7
8
9
10
11
12

National

13
1
1
•

Comment
Comment
«*»
«*
-

In the Fifth, Seventh, f nd F,i$?th Districts, the banks were
*ot identified as to type.*