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RECOMMENDATIONS OF THE FEDERAL ADVISORY COUNCIL TO THE FEDERAL RESERVE BOARD February 17, 1920 T O P I C N O . 1— Special rates for the rediscount o f bankers’ ac ceptances and the p olicy which should be pursued by Federal Reserve banks, having such rates, in their open market purchases. R ecom m en d ation : T h e special rate established b y Federal Reserve banks for the redis count o f bankers’ acceptances affords member banks the legitimate oppor tunity o f purchasing them, carrying them as a secondary reserve, and realizing on them prom ptly whenever they have occasion to do so. It also, however, affords them the opportunity o f purchasing them at current open market rates and having them rediscounted at the preferred rate simply for the profit in the transaction if this is permitted. It should be understood that the object o f the special rate is to en courage member banks to carry lines o f this class o f paper as a secondary reserve, prom ptly convertible into legal reserve balances when such conver sion becom es necessary. W ith such an understanding prevailing many o f the member banks w o u ld no doubt adopt the policy o f carrying lines o f bankers’ acceptances as secondary reserves and the market for them would thus be materially broadened. In some districts this has already occurred. T h e p olicy to be pursued therefore by Federal Reserve banks should be to leave the control o f the open market for such acceptances in the hands o f member banks and discount houses, so long as the former use the special rediscount rate legitim ately and d o not abuse it. T h e Federal Reserve banks should not therefore norm ally buy acceptances in the open market below the current rates at which the member banks and discount houses are buying them. Should it becom e urgently necessary to curtail rediscounts at the Federal R eserve banks rates can be raised and should it be found that the preferred rate for bankers’ acceptances is being abused such discrimination in their favor should be discontinued. T O P I C N O . 2 — R ates o f interest on deposits paid by member banks. R ecom m en dation : T h e C ouncil has had under consideration the rates o f interest paid on the several classes o f deposits by the banks located in the large cities o f each Federal R eserve District as shown in a statement prepared by the Federal R eserve agents and submitted to a conference o f bankers represent ing the twelve districts recently held in Chicago. A s the banks in the three central reserve cities and those in all other cities, where the rate o f interest paid on bank deposits has been regulated by the current rate o f discount at the Federal Reserve banks on ninety day com m ercial paper, have already taken action limiting the maximum rate o f interest to be paid on net and available daily balances o f banks and trust com panies to 2Y a c/ c an<^ as such action enables the Federal Reserve banks to increase their discount rate without reference to existing clearing house rules regulating the p ay ment o f interest, we are o f the opinion that no further steps are necessary or advisable looking to the regulation o f the rates o f interest to be paid on deposits. T O P I C N O . 3— Effectiveness o f the Federal R eserve Banks’ 6 ( r R ediscount rate. R ecom m en d ation : It is the opinion o f the Council that the Federal Reserve Banks’ 6 °?c rate for the rediscount o f ninety day com mercial paper has not been with out its effect on the credit situation but this rate has net been long enough in operation to determine whether or not it is high enough to effect the control desired. T O P IC bon ds: N O . 4 — Differential rates for loans secured by Governm ent R ecom m endation: In the opinion o f the Council the differential rates now established in favor o f loans secured by the Liberty and V icto ry loan bonds will ulti mately have to be discontinued but w e do not believe that the time has yet arrived when it should be done. T O P I C N O . 5— T h e Federal Reserve B oard recommends to C on gress that an additional pow er be granted it b y adding to subdivision ( d ) , Section 14, a proviso that each Federal Reserve Bank m ay, with the ap proval o f the Federal Reserve B oard, determine by uniform rule, applicable to all its member banks alike, the normal maximum rediscount line o f each member bank and that it may submit for the review and determination o f the Federal Reserve B oard graduated rates on an ascending scale to apply equally and ratably to all its member banks rediscounting amounts in excess o f the normal line so determined. In this w^ay, in the opinion o f the Board, it w ould be possible to reduce excessive borrowings o f member banks and to induce them to hold their own large borrowers in check without raising basic rates. R e c o m m e n d a t io n : T h e Council approves the principle o f applying regulatory rates to such banks as are m aking an excessive use o f the facilities o f the Federal Reserve Banks, but doubts the practicability o f establishing a normal maxi mum rediscount line app licable alike to all member banks. In determining the line o f discounts and loans to be granted to a member bank due regard must be given to the nature o f the business o f each member bank, as it is obvious that a bank serving a com m ercial clientele w ou ld legitimately require a larger rediscount line than one w hich did not serve customers w ho require considerable borrow in g facilities, and such bank should not be penalized for perform ing its proper function in financing com m erce and trade. T O P I C N O 6 — R a te o f interest at which future government certifi cates o f indebtedness should be issued. R ecom m en d a tion : If such certificates are to be o f short maturity, not exceeding three months, the C ou n cil believes they m ay be marketed if they bear a rate of 4 % % . If, h ow ever, they are issued to mature in nine or twelve months, it is the opinion o f the C ou n cil that a higher rate, bearing a closer relation to the rates current in the investment market, w ill be necessary in order to find a market for them. In either case a more general distribution o f them should be aim ed at and their concentration in the Federal Reserve banks as security for loans to m em ber banks should be discouraged. For this pur pose the F ederal reserve banks’ rate for loans to member banks secured by them should be not less than J/ 4 o f 1 % above the rate o f interest at which they are issued. T O P I C N O . 7— A r e balances due from foreign banks deductible from balances due to banks for the purpose o f determining reserves. R ecom m en d a tion : W e have read the opinion o f your Counsel undertaking to refute the opinions o f M essrs. Sherm an & Sterling, W h ite & Case, M ayer, M eyer, Austrian & P latt, Stetson, Jennings & Russell, and E dw ard E. Brow n, all eminent bank counsel, w h o agree that balances due from foreign banks can law fully be d ed u cted from balances due to banks for the purpose o f deter mining reserves in the manner provided b y Section 19, o f the Federal Reserve A c t . W e submit that the great preponderance o f counsel is on the side o f the opinion expressed b y us to the effect that balances due from foreign banks may legally be so ded u cted. W h o lly apart, however, from the legal ques tion on which the law yers seem to differ five to one, it is the opinion o f this C ouncil that the question should be considered and decided by your Board along the lines o f g o o d banking practice. T h e practice has heretofore existed and w e know o f no good reason why it should be changed now . A t the present time it makes very little difference to banks carrying foreign balances, as nearly all o f them have little or no balances due them in foreign countries. In normal times, h ow ever, these balances mount up into very substantial figures and there are no balances on their books more easily and more readily convertible into legal reserve balances with the Federal Reserve Banks than they are. In the interest o f financing the foreign trade o f this country, w e there fore again respectfully urge a reconsideration o f your ruling in this matter. T h e follow ing members o f the Federal at this meeting: Messrs. James B . Forgan, President; Philip Stockton, W . S. R o w e , F. O . W atts, C . T . Jaffray, R . L . B all, Grim, Secretary. A d v isory C ouncil were present President; L . L . R u e , V ic e J. G . B row n, O scar W e lls , A . L . M ills, and M erritt H . RECOMMENDATIONS OF THE FEDERAL ADVISORY COUNCIL TO THE FEDERAL RESERVE BOARD M a y 18, 1920 H on. W . P . G . H ardin g, G overnor, Federal R eserve B oa rd, W ash in gton , D . C . M y D ear S ir: T h e Council has given consideration to the matters included in your communication o f A p ril 1 7th, an^ beg to reply thereto in the follow ing man ner, follow in g the order set out by y o u : T O P I C N O . 1.— “ Causes o f continued expansion o f credits and o f Federal R eserve note issues.” A n sw e r: T h ere are m any contributing causes o f which the follow ing may be re garded as param ount: 1. W e recognize, o f course, that the fr?t cause is the Great W a r. 2. G reat extravagance, national, municipal and individual. 3. Inefficiency and indifference o f labor, resulting in lessening production. 4. A shortage o f transportation facilities, thus preventing the normal m ovem ent o f com m odities. 5. T h e vicious circle o f increasing wages and prices. T O P I C N O . 2 .— “ H o w can the reserve position o f the Federal R e serve banks be m aterially strengthened before the seasonal demand sets in next Fall without undue disturbance o f the processes o f production and dis tribution?” R e co m m e n d a tio n : B y urging upon m em ber banks, through the Federal Reserve banks, the wisdom o f show ing borrow ers the necessity o f the curtailment o f general credits and especially for non-essential uses, as w ell as continuing to dis courage loans for capital and speculative purposes; by checking excessive borrowings through the application o f higher rates. T O P I C N O . 3 .— “ If steps cannot be taken at this time leading to a more normal proportion betw een the volum e o f credits and the volume o f goods, when can they be taken? ’ R e co m m e n d a tio n : In our opinion steps should be taken now , as outlined in answer to the last question. T O P I C N O . 4 .— “ W h a t is the effect upon the general situation o f the increased Treasury borrowings and what should be the p olicy o f the F ed eral Reserve banks in establishing rates o f discount on paper secured by certificates o f indebtedness?” • i • R ecom m endation: It is obvious that the borrowings o f the Treasury have the same effect upon the general credit situation as those o f other borrowers. T h e Council would suggest the wisdom o f Congressional relief from the burden o f gov ernment financing b y a policy o f rigid econ om y; the revision o f the tax laws for the sake o f a more equitable distribution o f the burden without reducing the revenue; the enactment o f the budget system, the budget to include p ro vision for the gradual payment o f the short time obligations o f the Treasury. These w ould o f necessity preclude unwise appropriations, such as the pro posed soldiers’ bonus. In view o f the large volume o f Treasury Certificates o f Indebtedness carried by member banks at the instance o f the Treasury Departm ent, w e believe that rates established by the Federal Reserve banks on paper secured by them should not be materially greater than the rates borne by the Certifi cates. T O P I C N O . 5.— “ Should there be a revision o f rates on paper secured by Liberty bonds and V ictory notes?” Recom m endation; From a survey o f the present rates in force b y the Federal R eserve banks it w ould seem that six per cent is now being charged on paper secured by Liberty bonds and V ictory notes. In the judgment o f the Council when and if any further revision o f rates should be made there should be shown due consideration for the original subscriber o f government securities. (S ig n ed ) J a s . B . F o r g a n , President. T h e following members o f the Federal A d v isory Council w ere present at this meeting: Messrs. James B. Forgan, President; L . L . R u e, V ic e President; Philip Stockton, A . B. Hepburn, W . S. R o w e , J. G . Brow n, Oscar W ells, F. O . W atts, E. F. Swinney, R . L . B all, A . L . M ills, and Merritt H . Grim, Secretary. RECOMMENDATIONS OF THE FEDERAL ADVISORY COUNCIL TO THE FEDERAL RESERVE BOARD September 2 1 , 1920 T O P I C N O . 1— C R E D I T C O N T R O L . — 1. W h at are the objects sought to be attained by the policy o f credit control in the existing circum stances? Is the o b ject (a ) T o maintain or to strengthen reserves? (b ) To expansion ? stabilize the existing situation by prevention o f further (c ) T o bring about a discriminating deflation by reducing the total volum e o f credit? R eco m m e n d a tio n : From the statistics com piled by Professor Kemmerer o f Princeton, bank deposits increased from $ 1 2 ,6 7 8 ,0 0 0 ,0 0 0 in 1913 to $ 2 7 ,9 2 8 ,0 0 0 ,0 0 0 in 1919. A t the same time the ratio o f cash reserves to total deposits diminished from 1 1.7 in 1913 to 6. 6 in 1919. “ T a k in g the index numbers o f the United States Bureau o f Labor Statistics as the most comprehensive and most scientifically prepared of the index numbers covering the entire period 1913 to 1919 inclusive, we may say that the w holesale price level increased from 1913 to A pril, 1920, 1 6 5 % ; in other w ords, if one calls the dollar o f 1913 a 1 0 0 % dollar in its purchasing p ow er over commodities at wholesale, the dollar o f today is approxim ately a 3 8 % d olla r.” T h is was the condition o f affairs when the Federal Reserve Board undertook to exercise its pow er over credit for the purpose o f protecting personal and com m ercial interests. A ll experienced business men knew that prices w o u ld seek a low er level, by gradual process if good judgment and conservatism prevailed, or b y a commercial debacle if the illogical, ill-considered and extravagant methods brought about by the war were permitted to continue. U n d er these circumstances, and none too soon, the Federal R eserve B o a rd exercised its pow er over credit in order to con strain bankers and business men to exercise conservatism and help strengthen com m ercial and financial conditions. T h e B oard in so doing have accom plished a great w ork and have demonstrated one o f the powers for good which the F ederal R eserve System possesses. Naturally their first move was in the direction o f strengthening the bank’s reserves. That means strengthening the bank and putting it in a liquid position— in the position in which a w ell m anaged bank should always be, to respond to the de mands o f its clientele. Strengthening he reserves meant curtailing credit and ipso facto w ou ld prevent “ further expansion.” N o one wishes ti “ Stabilize” existing conditions, but to get awav from them to a safer and more conservative level. T h is w ou ld naturally bring about a “ Discrim mating deflation” by extending credit to such industries as were essential and needed support in order to preserve the general business w elfare, and by restraining credit to activities which though perfectly legitimate were nevertheless non-essential to the general w elfare and should be promoted by the funds c f their owners and managers, and net be allow ed to absorb commercial resources needed for the financing o f business closely connected with the public welfare. 2. Can a substantial reduction in the volum e o f credit be effected without injury to the legitimate business o f the country and without curtail ment o f essential production? Recom m endation: A substantial reduction o f the volume o f credit can be effected with out injury to the legitimate industry o f the country and without curtailing c f essential production. N ot only this but such reduction in volum e ot credit may be made to materially strengthen the credit fabric o f the coun try as a whole. T h e first and most beneficent effect o f the act o f the Federal R eserve B oa id m controlling credit was to arrest the attention o f the w hole coun try and to incur high commendation from conservative forces and incur criticism ranging from mild to violent from certain sections or interests. It made everybody stop and think and the discussion which ensued show ed plainly that the B oard v/as right. T h e psychological attitude c f the cou n try toward business immediately began to change and from w ild extrava gance and a disposition to enter into new and ill-considered business, there came about a feeling c f conservatism. P eop le began to ask themselves just where they stood, how much they were really worth, and how they w ou ld fare if called upon to liquidate their outstanding obligations. D rafts drawn against goods shipped abroad were not always paid and sometimes returned. People began to repudiate their contracts to receive goods, especially in cases where the price had receded. Competition in business has brought about a most unfortunate practice— people order goods and then if it does not suit their convenience, they refuse to receive and pay for the same. This has continued so long and is so much the custom that manufacturers and wholesalers, hardly expect to hold their customers to rigid fulfillment o f their contracts, if a change in the market or a change in business con d i tions makes it desirable for them to repudiate. Such repudiation o f pur chases began to happen generally and manufacturers and wholesalers found themselves possessed o f large volumes o f very high-priced goods wrhich they could not market without loss. T h at is the condition o f the m ercan tile industry in our country today. T h e y have for years dictated the price of their goods and they are now endeavoring to dispose o f them to the public without material abatement in prices. It is generally realized that they cannot accomplish such results; recessions in price have already set in and are bound to be more pronounced. Business people will have to liquidate their goods in order to liquidate financial obligations. T h is will bring about competition in selling throughout the country, something that has not existed for several years and this competition in its normal and natural course will clarify the situation and bring about normal conditions. 3. T o w hat extent has one or more o f these objects been attained in each District and in the country at large? R e co m m e n d a tio n : T h e o b je ct sought to be accom plished by the Federal Reserve B oard has been and is being accom plished in all Districts. 4. T o w hat extent is it necessary to distinguish between the immediate objective o f the p o licy o f credit control and the remoter objective, such as reduction in the cost o f living? R e co m m e n d a tio n : T h e immediate effect o f credit control is to safeguard the situation, to enable all business to function normally and the Board should at all times make this clear. A lth o u g h a logical result may be lower prices and low er cost o f living, it should distinctly appear that the Board does not seek to control or regulate prices, but leaves the price level to competi tion under the la w o f supply and demand. 5. W h a t is the proper conception o f the “ normal credit condition” which the F ederal R eserve Banks should seek to bring about? N ote: O b v iou sly if “ liquidation” or “ stabilization” o f the exist ing credit situation are to be regarded as the objectives o f the Federal R eserve p o licy o f credit control, a condition which can be regarded as “ norm al” w ill be attained very much more quickly than if the objective is a reduction in considerable amount o f the total volume o f credit. R e co m m e n d a tio n : T h e proper con cept o f “ a normal credit condition” is something that varies with the years, with the crops, with commerce, involving domestic and foreign exchange, and with all the varying influences that make up the activity o f a com m ercial nation. T h e making o f crops has to be financed. W h ile w e are greatly indebted to nature for her annual con tribution to the prosperity and happiness o f mankind, the volume o f that contribution depends very largely upon mankind’s activities. T h e latent resources so abundant and so valuable nevertheless must be exhumed and that costs time and m oney and is a regular business in itself. A normal credit condition w o u ld seem to be one in which funds were obtainable in sufficient volum e to enable the individual, the corporation, the great trans portation bystems o f the country, the municipality and the state to obtain funds at reasonable rates with which to prosecute their respective enter prises. T h is is not a static w o r ld ; there should also be funds available for new and enlarged enterprise, for installation o f new and improved meth ods and processes, w hich the inventive genius o f mankind is constantly producing. 6. M eth ods c f credit control. different methods c f credit control. Consideration of the efficacy of (a ) H orizontal increase o f rates, especially o f com m ercial rates; a canvass o f the experience o f banks w hich have put into effect a 7% com mercial rate, to wit, N e w Y o r k , B oston, C h ica g o and M inneapolis. (b ) Progressive rate schedules starting with 6 % as a basic rate; a canvass o f the experience o f Federal R eserve Banks o f Kansas C ity, D allas, St. Louis, and A tlanta. (c) O iher methods o f dealing with the situation, such as the implication that increased offerings b y member banks w ill force higher rates or recourse to the progressive rate; a canvass o f the experience o f Federal R eserve Banks o f C leveland, P hiladelphia, R ich m on d , and San Francisco. (d ) Restricting issues o f Federal R eserve notes to Federal R eserve Banks as a potential means o f enforcing credit con trol; can vass o f English experience and views. R ecom m en d ation : T h e different methods o f credit control have not had a sufficient test period for the experience o f the banks to be conclusive. It is found that each class o f banks holds its ow n method to be most satisfactory and in such a situation there should be further experience before w e cou ld give to the B oa rd any conclusion as between the three methods in use or advise any present attempt at uniformity in method. 7. Inter-Reserve Bank rediscounts as related to the problem o f credit control. Is the existing policy and practice with respect to such rediscounts satisfactory and sound? (a ) To effect an approximate equalization o f reserves? R ecom m en d ation : T h e existing policy with respect to Inter-Reserve B ank rediscounts is sound and the B oard is to be highly com m ended for the manner in which they have made it effective. (b ) A t the same rate fixed for its member banks b y the bank granting the accom m odation? Note: W h e n recourse was first had to inter-bank rediscounts it was thought that the value o f a Federal R eserve B a n k ’s endorsement was entitled to recognition in the form o f a reduced discount rate. M ore recently this idea has been abandoned and rediscount transac tions between Federal Reserve Banks are made at the rates estab lished for member banks by the Federal R eserve Bank extending the accom m odation. T h e question now arises, hcw ever, whether a F e d eral Reserve Bank which has been able to maintain high reserves by reducing the demands for accom m odation from its ow n member banks, which are its depositors, should be required to extend accom m odations to member banks in other Districts through the medium o f their F e d eral Reserve Bank at the same rates as are established for their own members. —10 — Recommendation: T h e rate o f such rediscounts should be variable and fixed by the B oard from time to time as the situation may appear to require and with out any special regard either for the profit or loss to the contracting banks. In the present situation w e approve the action c f the Board in fixing the rate o f such rediscounts at seven per cent. T O P I C N o . 2 .— L O A N S S E C U R E D A N D V IC T O R Y N O TE S. BY L IB E R T Y BONDS 1 . Is there any moral obligation resting upon any o f the Federal R e serve banks to establish rates low er than commercial rates for paper of this classification? R ecom m en dation : It is difficult fo r this C ou n cil to determine whether any moral obliga tion exists in any o f the F ederal R eserve Districts. O n the general proposition o f moral obligation arising out o f the meth ods adopted in the various L iberty B on d campaigns the Council is equally divided, voting 6 to 6 . 2. W o u ld liquidation o f leans c f this class be retarded or promoted by the establishment o f low er rates? R e co m m e n d a tio n : T h e establishment o f low er rates doubtless w ould retard the liquida tion o f loans b y L iberty B on d s and V icto ry Notes. 3. If low er rates are deem ed desirable, w ould it be equitable and practicable to have such rates apply to original subscribers only? R e c o m m e n d a tio n : It might be equitable to confine preferential rates to original sub scribers on ly, but w e are inform ed that you have been advised that it w ould riot be legal, and in our opinion it w ould not be practicable. 4. S h ou ld m em ber banks’ collateral notes be fully secured, taking market value instead o f fa ce value as a basis? 5. If so, h o w and w hen cou ld the new policy be put into effect with a minimum o f friction ? R e co m m e n d a tio n : Y e s. W e understand this is the practice in some districts and should be m ade general. — n — T O P IC NO. 3.— F E D E R A L R E S E R V E N O T E ISSUES. 1. Is the note-issue policy o f the Federal to legitimate criticism? Reserve System subject R ecom m endation: W e regard the note-issue policy under the Federal R eserve System as sound and therefore not subject to legitimate criticism. 2. W h a t connection is there between changes in the volume o f credit and the volume o f currency? 3. Is there any difference in relation to effect upon prices between the volume o f credit and the volume o f currency? A n sw er: It is not clear to the Council just what is meant b y these questions. T h e y are too involved to admit o f their being satisfactorily answered in the time at the C ou ncil’ s disposal. 4. Can the note-issue policy o f the Federal Reserve System be properly charged with any important responsibility for inflated prices, if so, what has been the responsibility and in what w ay does the issue o f Federal Reserve notes promote or assist inflation. R ecom m en d ation : A n increase o f the Federal R eserve note issue was m ade necessary by war conditions and doubtless had some influence in inflating prices, but in the opinion o f the Council there has been no undue issue o f these notes. 5. Can the accepted principles o f bank-note-currency regulation, applicable in normal circumstances when the com m erce o f the w orld is con ducted on a gold standard, be safely taken as a guide in the abnormal circumstances now existing, when the gold standard is virtually suspended, except in the U nited States and Japan? 6. In connection with the p olicy o f credit control should the present ncte-issue policy o f the Federal R eserve System be changed and restric tions be thrown around the issue o f Federal R eserve notes? 7. If the issue o f Federal Reserve notes should be restricted, what form should the restriction take and what effect w ou ld different methods o f restrictions have? (a Imposition o f charges against Federal R eserve notes upon the uncovered part o f circulation issued to them at a given rate, for example, a fixed rate o f 5 % or a rate varying with the com m ercial rate. (b ) W o u ld it be practicable to establish for each member ban a so-called normal currency limit and to impose charges upon member banks calling for notes in excess o f their limit? —12 — (c ) W o u ld it be advisable while continuing to have the Federal Reserve B anks pay all transportation charges on incoming currency, to have shipments o f outgoing currency m ade at the expense o f the con signees? (d ) Restrictions b y definition o f the character o f the paper acceptable as collateral b y the Federal Reserve A gent against the issue o f F ederal R eserv e notes. Should member banks’ collateral notes or custom ers’ notes secured b y Governm ent obligations be taken as collateral for F ederal R eserve notes? (e ) Lim itation o f the total volum e o f Federal Reserve notes by the F ederal R eserv e B o a rd , the maximum amount being fixed pro rata for each F ed eral R eserve Bank. ( T h e Federal Reserve Board has statutory p o w e r to a ccept in part or to reject entirely all applica tions for F edera l R eserv e n o te s). W o u ld restriction o f note issues in any o f the above mentioned ways operate to prom ote a better control o f credit, and if so, what w ould be the effect upon the com m erce and business o f the country? R e co m m e n d a tio n : W e k n ow o f no reason w h y the principles under which bank note currency as issued under the F ederal R eserve system should be changed as sufficient time has not elapsed to test its flexibility in response to busi ness conditions. T h e C ou n cil is o f the opinion that no alteration should be made in the regulations governing the currency issued which w ould impair its elasticity. T h e fo llo w in g m em bers o f the F ederal A d v isory Council were pres ent at this m eetin g: M essrs. James B . Forgan, President; L . L . R ue, V ice -P re sid e n t; P h ilip S tock ton , A . B . H epburn, W . S. R o w e , J. G . B row n, O sca r W e lls , F . O . W a tts, C . T . Jaffray, E. F. Swinney, R . L . Ball, A . L . M ills, and M erritt H . G rim , Secretary. - i:i -
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