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Released for publication
Morning papers, June 2U, 1935

>

1r

The Banking Bill
Considered in the Light of
1927 - 1929
By A. C. Miller
Member, Federal Reserve Board

Pronounced differences of opinion regarding the amendments to the
Federal Reserve Act proposed in legislation now pending in Congress,
a

*id more particularly the acute controversy which has arisen with regard

to the contemplated change in the location of the responsibility for the
exercise of the open-market authority in the Federal Reserve System, have
sharpened interest in Federal Reserve history, and especially those episodes in its history that throw light upon the wisdom with which its
0

Pen-market powers have been exercised in the past. The greatest in-

terest has been shown in the episode covering the period 1927-1929*
Severe judgment has been passed by many commentators upon the policies
Pursued by the Federal Reserve System during this interval.
Among these may be cited
(1) The opinion expressed by Professor Lionel Robbins, of the
University of London, in his recent brilliant volume "The Great Depression":
" . . . it was during this period (1927-1923) that the situation
il r
really out of hand. Why did this take place?
'
2S M
,n to

J

"The answer seems to be that It was the direct outcome of misdirected management on the part of the Federal Reserve authorities. ."
(2) The view expressed in the editorial in the New York Times of
Sunday, June 2, 1935, on the Banking Bill which appears to condemn not
only Federal Reserve policies during the period 1927-1929 but also to
charge the responsibility for the "unfortunate mistakes" to the Fedorkl Reserve Board:
"It has naturally been asked, whether these drastic changes were
suggested by the fact that the original distribution of authority, between Board and Reserve banks, had not worked well.

Episodes have been

cited, in the Reserve System's history, when the distribution of powers
operated badly—the Board's refusal of a higher discount rate in 1919
to check the wild commodity speculation; insistence by the Board, in
1927, on a lower discount rate at the Chicago Reserve Bank, despite the
evidence of growing speculation which the bank itself mistrusted, and the
Board's rejection, early in 1 9 2 9 , of the New York bank's move to raise
its rate and impose some obstacle to that year's ultimately fatal stock
speculation.

But the strange thing about this historical retrospect is

that all three unfortunate mistakes were made at Washington, against the
representations of the Reserve banks; yet that the new bill proposes to
enlarge the power of Washington and to restrain the Reserve bank's
initiative."
The view expressed in the New York Times editorial and frequently
expressed elsewhere that during the period 1927-1929 the Federal Reserve
banks were right and the Federal Reserve Board was wrong is based upon

partial and misleading information*

Such statements are made either

through lack of knowledge or in disregard of the following pertinent
facts:
(1) That the Board's actiofi in reducing the discount
rate of the Federal Reserve Bank of Chicago in 1927
was in pursuance of a System policy initiated by the
Federal Reserve Bank of New York and concurred in by
all but one of the Federal Reserve banks;
(2) That the Federal Reserve banks took no action to
check the growing tide of speculation between July
13, 1928, and February lU, 1929; and
(3) That the first formal proposal for an increase in
the discount rate from 5 to 6 percent came to the
Board on February lU, 1929, after the Federal Reserve
Board had sent to all Federal Reserve banks under
date of February 2, 1929. and had made public on
February 7, 1929, a statement v/hich undertook to
curb speculative excesses by a method which has
come to be known as "direct action."
Let it be admitted at the' outset that as a straight proposition of
law, so far as concerns the Federal Reserve Board, it must share the responsibility for any action taken by a Federal Reserve bank, whether
mistake or otherwise, with respect to discount rrvtes and open-market
Policies, Under the terms of the Federal Reserve Act, no change in

discount rates proposed by the Federal Reserve banks and no open-market
policy proposed by the Federal Open Market Committee can be put into
effect until it has been approved by the Federal Reserve Board; but it
is clear that action originates with the Federal Reserve banks. The
responsibility for initiative vests in them. The primary responsibility is, therefore, theirs; the secondary and ultimate responsibility is
the Board's, This mast be borne in mind in any attempt to licate in
any other than a formal and legal sense the actual responsibility for
errors charged to the Federal Reserve System in the critical period
1937 to 1929.
It is because of the bearing that a truer and fuller understanding
of the manner in which the Federal Reserve banks and the Federal Reserve
Board have discharged their respective responsibilities has upon pending
banking legislation that a clearing up of these misapprehensions takes
on urgency at this time. And it is because of this that I here propose
to recite as briefly as I can the facts which are essential to an understanding of the course of Federal Reserve policy during the period 1927
to 1929*

I shall endeavor to do this in a way that will make it easy to

distinguish statements of fact from any comment I may offer on the facts,
done, X shall endeavor to draw conclusions that are relevant in ray
opinion to an understanding of the problem of Federal Reserve reorganization raised in Title II of the Banking Bill of 1935 now pending in
Congress,

To facilitate brevity of exposition and to focus attention more
quickly upon the material points I shall state and answer a series of
questions.
(l) What was there in the economic and financial situation
in 1927 that caused the adoption "by the Federal Reserve
System of an easy money policy during that year?
The record shows that in the summer of 192 7 there appeared a dowiw
ttard tendency in industrial production (Chart l) and that commodity

PHYSICAL VOLUME OF INDUSTRIAL PRODUCTION
PER CENT

A D J U S T E D FOR S E A S O N A L VARIATION, 1 9 2 3 - 2 5 A V E R A G E = 1 0 0

p

140

E R

C E N T

140

1922

1923

1924

1925

1926

Chart 1

1927

1928

1929

1930

.6.
Prices (Chart 2), which had been declining since the autumn of 1925,

WHOLESALE PRICES

Chart 2

We

re at the lowest level in five years, There was apprehension that this

downturn in business might foreshadow the coming of a depression* A
^rked decline in production and employment in the durable goods industries did, in fact, develop in the last half of the year.
In addition to disquieting domestic factors in the economic situa^Uon i n 1927, the European monetary and financial situation, particularly
as

it might affect the United States, was far from satisfactory. European

c

^rrencies, and particularly sterling, were showing weakness. It was fear,

that this would interfere with sales of our agricultural products in the

autumn months*

Considerable conccrn was also felt regarding the posi-

tion of the gold standard in those European countries which had already
restored it and also regarding the prospects of its early and successful restoration in others which had the matter under consideration,
(2) What were the objectives of the policy then
developed?
It may be said that the objective of Federal Reserve policy in 1927
Was to set in motion such forces as the System could command to counteract the recessionary forces which were in evidence, To this 6nd there
v.ras developed and adopted a policy of easing both the domestic and the
international financial situation by purchasing securities in the open
market and by reducing discount rates, thus cheapening the cost of credit
to borrowing member banks.
To relate the sequence of these open-market operations and discount
r

ate changes, without going into too much detail, the following summary
suffice:
The policy began in May 1927 with purchases of United States Govern-

ment securities by Federal Reserve banks, which carried their holdings
f

rom $300,000,000 in May to $600,000,000 in December, As a rosult of

these operations member banks were able to meet gold withdrawals of
$200,000,000 and to increase their reserve balances by over $100,000,000
without being under the necessity of increasing their borrowings from the
Reserve banks. (Chart 3)#
Educed from k to %

Discount rates at all the Reserve banks were

percent during the third quarter of the year.

g

MEMBER BANK RESERVES,
RESERVE BANK CREDIT, AND GOLD

Chart 3

Money rates in the open market soon declined (Chart H), sterling
^change advanced, and in time there was a considerable outflow of gold
fr

om the United States to other countries.

MONEY RATES IN NEW YORK CITY

Chart 4

(3) Was the p o l i c y s u c c e s s f u l i n achieving its

objectives?
It wa3i
Was

The tide of business recession or depression, whichever it

> was arrested toward the end of the year 1927-

The production curve

turned sharp']y upward and except for a halt of short duration in the
8

Pring of 1Q2S maintained a steady asceat until the sunder of 1929 (Chart
Prices of farm and related products shewed a marked rise in the latpart of 1927 and in 1928 the general level of wholesale prices was

characterized by relative stability.(Chart 2), The European currencies,
Notably sterling, strengthened and, in general, tension in the European
financial situation was considerably relieved.

So far, then, as the policy of mid-summer 1927 v/as instrumental
in resisting the forces of business depression, stimulating production, giving stability to the price level, and strengthening foreign
currencies, it must be pronounced to have been successful* Wore this
all that there was to the episode, it might be regarded, as many felt
disposed to regard it at the time, as a brilliant exploit in central
"bank policy and as a demonstration of the reasonableness of the belief,
which existed in the minds of many economists and others at the time,
that through well-conceived and well-timed monetary policy the terrors
of the business cycle could be largely if not wholly removed and price
stability and economic prosperity be insured under the operation of the
Federal Reserve System, It will not be forgotten that by many the
opening of the year 1928 was heralded as the beginning In these respects, as well as in many others, of a "new era3"
Unfortunately the 1927 policy of the Federal Reserve had other
effects besides those which were sought imd intended,

In the light

the longer perspective in which we can now view these other and
farther effects they stand out as the larger and more serious consequences of the policy then initiated and pursued. But before
leaving the year 1927 there is a further question with reference to
which remains to be considered,
(*+) Who proposed the policy pursued?
The policy above outlined was originated by the New York Federal
Reserve Bank, or more particularly by its distinguished Governor, the

11.

late Benjamin Strong, Brilliant of mind, engaging of personality,
fertile of resource, strong of will, ambitious of spirit, he had
extraordinary skill in impressing his views and purposes on his
associates in the Federal Reserve System, His ideas began to develop in the spring of 1927, but his program was not shaped until
after conferences with representatives of the three great European
central banks, who visited the United States in the summer of that
year, This program was then presented to the Federal Reserve System
la informal conferences with Federal Reserve bank governors, proposed
to the Federal Reserve Board and approved by it, and participated in
ty the Federal Reserve banks with dissent on the part of only one* The
Federal Reserve Bank of Chicago was reluctant to fall in line with the
reductions of discount rates that were being made at the other Reserve
^anks, and its rate was finally reduced by the Federal Reserve Board,
The general policy adopted at the time, therefore, was a System
Policy, conceived and initiated by the Governor of the New York Reserve
Bank, but approved at a meeting in July participated in by the Open
Market Committee, which consisted of five Reserve bank governors, by
Members of the Federal Reserve Board, and by two governors and one
cil

airman of mid-western Reserve banks.

It was not, as might be in-

ferred from the Times editorial, a policy either developed or imposed
the Board on the Reserve banks against their will. It was distinctly a Reserve bank policy.

The Federal Reserve Bank of Kansas City reduced its rate from k
to

percent on July 29J other Federal Reserve "banks reduced their

rates in quick succession^ St, Louis on August k; Boston and New
York on August 5; Cleveland on August 6; Dallas on August 12? Atlanta
on August 13; and Richmond on August l6*

The directors of the Chicago

bank, the second largest bank in the System, delayed action until the
Federal Reserve Board reduced its rate on September 7t

accordance

with the System policy. Thereafter, the Federal Reserve Bank of
Philadelphia reduced its rate on September 8; San Francisco on September 10; and Minneapolis on September 13»
The reductions in discount rates, except in the case of Chicago,
were authorized by the boards of directors of the respective Federal
Reserve banks and approved by the Federal Reserve Board, The action
the Board in reducing the rate at Chicago was taken after funds
began to move away from districts in which rates had been lowered, a
development which appeared to jeopardize the achievement of the genial objective of the System's policy, a necessary part of which was
the maintenance of easy conditions in the New York money market,
(5) What further results ensued?
Effects of oheap and abundant credit during the autumn of 1927
We

re not limited to stimulating business and production and to sus-

taining the price level and the European exchanges. Cheap credit

.13.

Save a further great and dangerous impetus to an already over expanded
credit situation, notably to the volume of credit used on the stock
exchanges (Chart 5), and to a further rapid upward flight of security

1

lK

prices (Chart 6), In consequence, the Federal Reserve System was con-

STOCK PRICES
421 COMMON

STOCKS

INDEX OF STANDARD STATISTICS CO., 1926=100

PER CENT

P E R CENT

250

250

A

200

A\

150

100

200

150

100

.'4A
50

50

0

0
1922

1923

1924

1925

1926

1927

1928

1929

1930

Chart 6

fronted toward the end of the year 1927 with the problem of getting control
the fund of credit which it had been instrumental in placing in the mar«
i
and keeping it within the bounds of safety lest an uncontrollable and
disastrous speculative situation shoxild develop. In consonance with this
attitude the Federal Reserve System abandoned the policy it had been pursu>
a

6 of offsetting exports of gold by the restoration of a similar volume o:

C3?e

<Ut to the money market through the purchase of United States Governmen

Purities, and allowed exportation of gold to exert their tightening

.15.
effect on the money market* The effect, however, in the situation
then existing was not very considerable. The stock market expansion
had acquired too much momentum.

It was evident that its pull was

too strong to be counteracted by gold withdrawals.
An added factor of adverse character arose out of the exigencies
in connection with the conversion of the Second Liberty Loan^ The
Treasury found that actual cash outgo for redemptions in connection
with its refinancing program outran its current cash intake and was,
therefore, carried by the Federal Reserve banks for a period of about
a

month on overdraft in varying amounts up to as much as $200,000,000,

^ith an average during the period of about $70,000,000, thus neutralizing to that extent the policy of the Reserve banks.
Total loans and investments of member banks during the second
kalf of the year 1927 showed a pronounced upward movement. There
an active demand for funds in security markets, both in connection with speculative trading and with the issuance of new securities,
There being an abundance of loanable funds, with no considerable demand
for

loans from business, the funds held by the banks went into invest-

ments and loans on securities. Bank loans to security brokers in New
increased during 1927 by about $600,000,000,

(Chart 5)

RESTRICTIVE POLICY IN FIRST HALF OF I92S
In the first half of 192S the Reserve System took successive measures
to check the further expansion of bank credit. Approximately $*KX),000,°°0 of United States Government securities were sold from the System's

16.

holdings. Discount rates were raised from 3i percent to b percent byall Federal Reserve banks between January 25 and March 1, to UJ- percent between April 20 and June 7» an d to 5 percent by 8 banks in July,
Sales of securities by the Reserve banks and further loss of gold,
amounting to $250,000,000, forced member banks to borrow at the Reserve
hanks. Bills discounted rose to over $1,000,000,000 for the first time
since 1921, (Chart 3) Call loan rates rose to over 6 percent by the
middle of the year. The increase in brokers1 loans by banks was definite,
ly checked,

(Chart 5)

Tho3e by New York City banks for their own ac-

count declined considerably. Brokers1 loans by non-banking lenders,
however, attracted by high rates, increased more rapidly than before,
The rise in stock prices was interrupted early in the year and again in
raid-summer, but these were but brief interruptions,

(Chart 6) There-

after evidence was accumulating that the speculative boom had become so
intrenched and was exercising such a pull that an increase in the cost
of

bank funds appeared to be no longer sufficient to chock it and more

extraordinary forms of control had to be considered.
Under conditions existing in previous stock market booms the measure;
adopted by the Reserve System might have been sufficient to check the
speculative expansion, but this was a new situation.

In the first place,

the astonishing increase in the earnings of largo corporations and the
e

*tremely low rates of interest at which money could be borrowed appeared

to supply a basis for the high prices that were being paid for stocks of
companies whose earnings were rising and whose dividend disbursements,
n

°t only through extra dividends but through regular dividends, were far

above the going price of money. To put the matter bluntly, the market
was actively engaged in recapitalizing the values of securities on the
basis of exceptional earnings and artifically low interest rates for
tooney, Secondly, the fact that banks could in an emergency rediscount,
as was not the case in stock market booms of the pre-Jederal Reserve
Period, inclined the banks to feel that they could expand in the assurance that in case of need they could turn to the Reserve banks for
Assistance; and thirdly, the supply of non-banking funds available for
"street loans" was larger than on any previous occasion. Consequently,
whereas in earlier periods call money rates in a crisis rose to 20, Uo,
and even 100 percent, in the first half of 192S the rate did not rise
a

^ove g percent, Higher levels were reached later, but never over 20

Percent, and that for only a few hours.

.18.
PASSIVE POLICY IN THE LAST HALF OF 1928
No further measures of restraint were adopted by the Federal Reserve System in the latter half of 1928. This was due in
part to the expectation, based on previous experience, that the
seasonal demands for funds in themselves would act as a tightening and restraining influence. There was also some fear that with
money rates at the prevailing high levels crop-moving and other
business activities might be severely handicapped.
These expectations were not realized owing to developments
in the acceptance market. The Reserve bank buying rate for bankers' acceptances had been advanced, but at 4 1/2 percent was still
below the discount rate. There was a heavy demand for acceptance
credits at

the time, and metropolitan banks were able to obtain

Reserve bank .funds at rates below the discount rate through the
creation of acceptances and their sale to the Reserve banks. The
banks, therefore, were able to expand their security loans without going further into debt at the Reserve banks. In fact, the
Purchase by the Reserve banks in the New York money market of accaptances in large volume onabled the member banks actually to
reduce their indebtedness to the Reserve banks at the very period
when restraint of speculation should have continued to be Reserveb

ank policy.

(Clmrt 3) Brokers' loans by both banks and others

increased rapidly (Chart 5) and bank loans on securities to others
than brokers also increased, Stock prices rose rapidly.

(Chart 6)

Money rates on acceptances and commercial paper did not rise in

19.
this period but rates for "street loans" rose sharply, reflecting the
intensity of the demand for such loans. (Chart 4)
In the face of these developments, the Federal Reserve System
failed to pursue affirmatively the policy of restraint adopted in the
°arly part of 1928. Taking the period from mid-summer of 1928 until
t

he early days of February 1929, the policy pursued by the Federal Re-

serve System may be characterized in the light of all that is known
n

°w, and much of which was visibly in process then, as a policy lackin strong conviction with regard to current developments profoundly
feeting the Federal Reserve System, the banking system, and the eco-

nomic and financial condition of the country.
In attempting to locate and assess responsibility for the delay
inactivity of the Federal Reserve System during the second half of
th
6

year 1928, the incontrovertible fact is that during this period as
as during the preceding year the leadership of the Federal Reserve

Astern rested with the Federal Reserve Bank of New York. There is no
attempt here to deny the responsibility of the Federal Reserve Board,
w

ithout whose sanction no steps could be undertaken. But the responsi-

bil
of the Board was secondary. Its mistake was in waiting too long
befity
OT,
assuming active leadership in firm intervention in the situation.

Partial explanation for the hesitancy on the part of the Board at this
tim
e

> in the absence of proposals for action from the Reserve banks, may

be

found in the Federal Reserve Act itself and in the tradition that had
0vm U

pol

P in the System. This tradition was that initiative in credit

icy should originate with the Federal Reserve banks, and that the

20.
Board's function ordinarily should be to approve or disapprove proposals brought forward by the banks.
In the critical situation which developed in the second half of
the year 1928 the Board followed the course of waiting for proposals
by the Reserve banks to be submitted to it for review. No such proposals were made.

It Is true that on some occasions the Board had

assumed a more positive attitude in the matter of the determination of
ji

count rates, but on the last occasion on which it had aggressively
intervened (the reduction of the Chicago rate in 1927) the reaction,
k°th j n public and governmental circles, had been generally unfavorable.
That the responsibility of the Federal Reserve Board was great,
Would be the last to deny. But it erred chiefly in following the
m r

° e customary course indicated by the law and by practice rather than

adopting a bolder course which might have been possible under the law
Was

not clearly made the Board's responsibility.

Looking at the natter in a practical way, it will be recognized
ari

d it should not be overlooked in this connection that the unfavor-

able public reaction to the assumption by the Board in the Chicago rate
c

°ntroversy in 1927 of authority to force rate action by Federal Reserve

bo.il k<?
° was not calculated to stimulate its sense of responsibility for
PP^opriate and tinely Federal Reserve policy. There is a great dif°nce between the power to initiate action and the authority to reView

Proposals after they have been made.
Wo one can toll whether the policies of the Federal Reserve Sys-

te,n

in 1927 and 1928 would liave been different had the Board had full

21. .
responsibility for action. But it is abundantly clear that acceptance
by

the Board of aggressive easing action proposed by the New York Fed-

eral Reserve Bank in 1927 and of complete abandonment of restraining
action in the second half of 1928 proves that the Board, under the established tradition, was first too quick to fall in with a daring and
dangerous proposal and Later too slow to assume the leadership which
Was

deeded and was lacking at a most critical time. It is my belief

that, if the Board had had full responsibility in the matter, it would
n

°t have adopted so readily the easing program of 1927 and would have

a

°ted more promptly in assuming leadership after July 1928.
But be this as it may, as tilings then were in the second half
1928 the Board looked .for the initiation of further measures of re-

straint to the Federal Reserve banks and they, in turn, depended on the
leadership of the Federal Reserve Bank of New York. And New York's leadership proved to be unequal to the situation.
An inquiry why Federal Reserve bank leadership erred during this
Period would make an illuminating and most instructive contribution to
problem of how to secure a more continuously effective leadership
^ responsibility in Federal Reserve administration.

One observation

be made and that is that the supercharged atmosphere of the country's
&reat financial and speculative center is not one which can be said to
conducive to sustained detachment of mind and interest or to a clear
^rspectiyg with regard to current developments and their implications
When -t-Vi
44 T

<ne tempo is as swift'as it was in this period of optimism gone

^d and cupidity gone drunk. However this may be, it is a fact that

22.
Whlle the
anci

attitude of the Federal Reserve banks was one of tolerance

temporizing and the Federal Reserve System as a whole was, as I

^ve elsewhere stated, "drifting" in the midst of a perilous situation
that called for intervention, the Federal Reserve Board was growing
m

° re

a n d rnorG

anxious at the course of developments. Ultimately its

^xiety reached a point where it felt that it must itself assume the
responsibility of intervening in the dangerously expanded and expandln

g speculative situation menacing the welfare of the country. This
did

early in February 1929.

BOARD'S DIRECT ACTION POLICY IN 1929
On February 2 the Board directed a letter to the Federal
Reserve banks ana on February 7 it issued a statement to the public carrying the substance of the letter previously addressed to
the banks, in which, after expressing its anxiety with regard to
current developments, it laid down an interpretation of the Federal Reserve Act under which it was stated:

"The Federal Re-

serve Board neither assumes the right nor has it any disposition
to set. itself up as an arbiter of security speculation or values,
is, however, its business to see to it that the Federal Reserve banks function as effectively as conditions will permit.
When it finds that conditions are arising which obstruct Federal Reserve banks in the effective discharge of their function
°f

So

managing the credit facilities of the Federal Reserve Sys-

tem as to accomodate commerce and business, it is its duty to
inquire into them and to take such measures as may be deemed
suitable and effective in the circumstances to correct them;
w

hich, in the immediate situation, means to restrain the use,

either directly or indirectly, of Federal Reserve credit facilities in aid of the growth of speculative credit."

This inter-

pretation was the basis of what soon came to be known as the policy of "direct pressure." It was, in brief, a method of exercising restraint upon the speculative credit expansion then in process by restricting the borrowings from the Federal Reserve banks
those member banks which were increasingly disposed to lend
f

unds for speculative purposes.

24.
It should bo particularly emphasized and noted that not until the
BOard thuB

doclared

lts own

attitude and the position which it deemed

appropriate for the Federal Reserve System as a whole did the Federal
eserve banks come forward with proposals for discount rate action
•Ooking to restraint of credit. It was on February 14, twelve days
after ^ u
* the Board's warning letter, that the Federal Reserve Bank of
New v i s u b ^tted to the Federal Reserve Board its recommendation that
itQ rj '
recount rate be raised to 6 percent.
for

This was the first proposal

an advance in discount rates to reach the Board after the 5 percent
6 V/as

established in July of the preceding year.

Thereupon an acute controversy extending over a period of months
oped between the Federal Reserve banks and. the Federal Reserve
ard WltH r e f G r o n c e t0

the respective merits of the policies of con-

^hrough discount rate advances and through "direct pressure."

It
8

the theory of discount rate advances that they increase the cost

4
°f
- +to vborrowing member banks and thus tend to restrain borrowings.
^ crediJ*

binary circumstances, and especially when the discount rate of a
serve v i •
) U m 18
abreast of or above going m.mey rates in the market, the
®ethocl of , + it*
controlling an expanding situation through discount rate incase u
,
aa. xiequently proved efficacious. But in such a situation as
listed i r
in the opening months of 1929 with the rate for call money
luctu + *
between G
and 20 percent, it would have been necessary to
Ste
P Up hv i -j
reueral xtoserve bank rates to unprecedented levels in order to
c
atch u
P Wlth the
rapid ascent of rates in the open money market.

.25.
To have done that would have involved damaging disorganization
°f the whole structure of commercial money rates, with economic
consequences that could not be accurately foretold and might
easily in the then existing situation have proved disastrous.
A prompt and energetic stepping up of the discount rate in the
earlier stages of a pronouncod credit and speculative expansion
mi

ght have been relied upon to exercise an effective restraining

and corrective influence, but when the rate of speculative expansion had attained such speed and the thirst for credit had
attained such intensity as was the case at the beginning of the
year 1929 and earlier, control through discount rate increase,
to put the matter mildly, is at best to be regarded as a frail
reliance and a dubious expedient.
In the circumstances which existed at the time when the
Board made its announcement with regard to "direct pressure" the
speculator did not ask what was the cost of money but whether he
could get it at any price. The increase of rate might even have
been a relief to the speculative market inasmuch as it would have
carried the suggestion, whether so intended or.not, that money
V/Q

ulci be forthcoming from the Federal Reserve banks so long as

the stipulated price for it was paid.

"Direct pressure," on the

°ther hand, works as the name indicates, by direct control of member banks instead of indirectly through money rates. As applied
1929, it put the member bank, which was seeking Federal Reserve
Cr

edit facilities in order to support or increase its extensions

26.
of credit for speculative uses, under pressure by obliging it
t o sho;v

that it was entitled to accommodation, and leaving un-

disturbed such member banks as were borrowing in the usual course
f

rom their Federal Reserve banks for meeting commercial require-

ments

I t was

-

>

brief, a method of exercising a discriminate

control over the extension of Federal Reserve credit such
as

the purely technical and impersonal method of bank rate could

not do.
od

"Direct pressure," furthermore, is a more flexible meth-

ot control, capable of easy adjustment, if circumstances should

(i0:n nd

^ -

9y comparison, the discount rate is a more formal device,

0 TV"!
one that in a rapidly shifting scene is rigid end clumsy,
4. J

-sure can easily be increased or diminished through direct ac-

'

Change of discount rate, because it is a more formal and

Public proceeding, takes on the aspect of a signal indicating
change of direction or change of policy, and therefore is less
likely to be invoked promptly as soon as indications of changes
in +•ne
v> situation become discernible. To put it bluntly, though
U O t elti

£antly, control by rate miction in a speculative gale of

SUc

h fury

a g sv/ept t h e U n i t e d

states in 1929 is a good deal like

s

Pitting against the wind.
The Board's opinion that "direct pressure" would afford

°tj onl y 0 method more appropriate in the circumstances than a
di
s
°ount rate increase but also one likely to prove highly suec e Q ci ui
p, i in putting an effective pressure upon the hitherto exPcind *

volume of speculative credit was vindicated by the in-

27.
flue nee this policy exerted shortly aft-r the beginning of its
application.
From the beginning of February until the end of May brokers'
loans by reporting member banks declined by about $650,000,000;
and although brokers' "loans by others" continued to increase,
the total of brokers' loans showed a net decline in this period.
(Chart 5) Money rates increased sharply.

(Chart 4) Stock

Prices, which had been rising rapidly, fluctuated within a comparatively narrow range.

(Chart 6)

By the middle of June it became apparent that in the then
existing psychological and economic situation continuance of unremitting pressure on the market, particularly with the known
heavy financial requirements of many leading industrial undertakings at the approaching end of the fiscal year, might precipitate a catastrophe. The Board, after a conference with a delnation of New York Reserve bank directors, decided to relax for
the time being but not to abandon its "direct pressure." It was
Moreover then becoming evident that the stock market was readin g c, point where it would collapse of its own weight, and that
th

e principal concern of the Federal Reserve System should be to

Prepare itself to help the banks and the country to absorb the
Eminent shock as soon as it occurred.
It is not without significance in current discussions as
to

the proper distribution of authority between the banks and the

Board, that during the tension occasioned by the acute differences

28.
over the leadership of the Federal Reserve System in the six
months following the Board's declaration of its position of February 2, 1929, the five members of the Board who took the responsibility of formulating the attitude and policy for the Federal Reserve System were opposed by a minority of their own membership,
including the Secretary of the Treasury, the Governor and the ViceGovernor, by the twelve Federal Reserve banks, and, finally, by
the Federal Advisory Council and many, but by no means all, of the
•Largest member banks. This was a formidable opposition. 'Nevertheless the Board adhered to its position, firm in its conviction
"that it was pursuing the only proper and effective course of action, belated though it was, which was open to the Federal Reserve System at the time. That it did not err in its judgment
from a public point of view seems sufficiently established by the
•fact that several of the most important amendments written into
th

e Banking Act of 1933 with regard to the Federal Reserve System

were based upon the attitude of t,he Board as expressed in 1929
ar

*d the procedures then developed. This was a ratification ty

the Congress of the United States of what had been undertaken by
the Board in the early months of 1929 in the face of determined
distance.

.29.
CONCLUSION
Looking at the record of this period 1927-1929, as thus
briefly recited, certain conclusions, I believe, will suggest
themselves to anyone who is seriously interested in drawing from
this chapter of Federal Reserve experience lessons which are
Pertinent to the pending discussions with regard to the modification of the Federal Reserve System. More particularly these
Wessons have a bearing on that phase of th«j proposed legislation
which would provide a more definite concentration of authority
0v

er the opon-rnarket policy of the Federal Reserve System by

Placing the ultimate responsibility with the Federal Reserve
B

°ard in place of the existing system which divides responsibility

b y Ves

ting the power to initiate policies in the Federal Reserve

b

*nks and the power to ratify or veto them in the Federal Reserve
card. The first of these lessons clearly points to the inad-

vi

sability of a division of responsibility in a matter of such

V l t a l na

tional moment.

In its actual working, whatever might be

s^id for the existing system theoretically, it has not produced a
satisfactory result, as the 1927-1929 experience appears clearly
0

demonstrate, and it has not done it, in my opinion, because the

Responsibility has been divided.
Unity of responsibility, my experience with the Federal ReServ

e System has demonstrated, is essential to the ceaseless concern n ^
and vigilance which arc necessary for timely and vigorous
ac t i

°n in matters of central banking policy and administration.

30.
THE LESSONS OF THIS EXPERIENCE
Looking at the record for the period 1927-1929, as thus briefly
^cited, certain conclusions appear to suggest themselves to anyone
wh

° is seriously interested in drawing from this chapter of Federal

Reserve experience lessons which are pertinent to the pending discussions with regard to the modification of the Federal Reserve System,
a

nd more particularly that feature of the proposed legislation which

would provide a more definite concentration of responsibility for the
open-market policy of the Federal Reserve System:
(1) Hie authority to initiate policies carries with it the
opportunity to exercise leadership and involves a far greater degree
Of T>

responsibility than the mere authority to approve or disapprove
Policies initiated by others.
(2) The body which initiates a policy should be under obligati
to watch its consequences and to inaugurate a change whenever
°lrcumstances make it advisable.

In other words, responsibility

sh

°u.ld be continuous.
(5) The judgment of the bankers or of officers of Federal Re-

Se

rve banks regarding national credit policies has proved itself not

to b

e infallible, and they cannot always be trusted to reverse their

Policies promptly when the public interest requires such action.
(4) The authority to initiate national credit policies should
be

concentrated in a single body which should have definite responsiity to the public not only for the initiation of policies but also
following them through, watching their effect and initiating

31.
changes or modifications when the public .Interest r<•equires.
WHERE SHOULD RESPONSIBILITY BE PLACED?
This brings us to the question in what body should such authority
and

responsibility be concentrated.
It is my conviction that it should be lodged in a body, no mat-

4.

r how

constituted, having o. national viewpoint and owing undivided

allegiance to the general public interest.

Its judgment should not

be

carped by the viewpoint of any particular s-ction of the country

0r

by the special interests of any particular group.

It should be an

^partial, independent body with a keen and continuous sense of public
ClUty a n d a

Point of view sufficiently detached to avoid having its

Ju

tfgment as to long-time policies swayed by the popular clamor of the

moment.

PLAN ADOPTED BY HOUSE OF REPRESENTATIVES
The pending banking bill in the form in which it was passed by
the
aik

House of Representatives provides for the creation of an Open
et Committee consisting of five representatives of the Federal

Reserve banks, which would have power to propose open-market policies
and

changes in discount rates ai:d reserve requirements.

The final

authority over these matters and the final responsibility for them,
how
cver, would be vested in the Federal Reserve Board, which could
a w

Prove or disapprove the policies recommended by the Open Market
C m
° mittee, and could also initiate open-market policies, changes in

32.
discount rates and reserve requirements, and would have definite
authority to enforce any policies initiated or approved by it with
respect to these matters. At the same time, the Board would be reQuired to consult with the Open Market Committee and obtain its views
before initiating such policies.
This would insure consideration of the banker viewpoint but
would vest final power and responsibility in a national body responsiv e to the country as a whole.

It would provide concentration and

continuity of authority and responsibility and would enable the public
to

know at all times exactly whom to hold responsible for national

credit policies.

DEFICIENCIES IN PLAN ADOPTED BY HOUSE
With all the undoubted merit that it possesses, this plan has
Nevertheless been the subject of criticism and, in my opinion, reV8dls

deficiencies which should be corrected before final legislation

is enacted. These deficiencies and criticisms and the measures
w

ich I have suggested for their correction may be summed up as fol-

lows:
^

Committee merely advisory
Under the House plan, the Reserve banks are given a merely ad°°ry status in connection with the formulation of open-market

Policies, instead of the status which they now have of responsible
p3?0

Ponents of open-market plans.

53.
As not infrequently occurs where a body has a merely advisory
^unction, it may reasonably be expected that the advisory committee
^presenting the banks will not bake the same deeply serious interest
a

*d make the same conscientious effort to do its best and fight for

1

ts conviction as would a committee with authority, and therefore

w

ith. definite responsibility for the exercise of judgment leading to

a

°tion.
X have, therefore, proposed that the Open Market Committee

sh

ould have authority and responsibility to initiate open-market poli-

o s , subject to review, modification, and determination by the FedRos
lts

°rve Board; but that the Federal Reserve Board should be given

full share of responsibility by having authority to initiate polis as well as authority to approve or disapprove, 'with or without

od

ification, the policies initiated by the Committee.

^

limited Reserve bank representation
Even in the advisory status given to the Reserve banks, under

the
Q

Plan adopted by the House of Representatives, only a limited

^umber (5) o f

t h e R o G e r v o b a n k s V/ould

have a voice in the proceedings.

In a matter of such vast consequence to the whole country, this
be regarded as a grave defect, one indeed which was recognized
^

the Federal Reserve Board itself and the Federal Reservo System
W generally when the Board in 1950 enlarged the membership of
e

then existing Open Market Committee from a membership of five to

Membership including representatives of all the Federal Reserve banks.

34.
It should not be overlooked that there is no science of openmarket policy. Determination of such policy is at best a matter of
Judgment, in which many factors other than merely economic factors
must be reckoned with.

There is no invariable yardstick for measuring

G V e n t3 e

^ economic factors, still less is there one for measuring the

imponderables. Wisdom in these matters may in the future, as has
sometimes been the case in the past, proceed out of the mind of the
spokesman for one of the smallest and outwardly least important of
the Federal Reserve banks. There is an advantage in giving to the
discussions of open-market policy questions a broad base by letting
eac

h Reserve bank have a voice.
It will not be overlooked in this connection by students of

American political and social development that the original structure
of

the Federal Reserve System follows in its regional character the

an

al0gj>es
o u r American structure and history. By adherence to
th *
principle we can avoid any occasion or pretext for sectional
a

nimosity or the suspicion that the credit policies of the Federal

^eserve System are not national in their source and inspiration.
Amei
"ica: is still American; and a strong, vital, and organic American
na

tionalism must derive much of its real strength and enduring solidity

^om the contribution derived from a vigorous and robust spirit of
local
A

j
and regional self-respect, when it is accorded an opportunity

Participate in the making of national policy in any field and
specially in the field of credit and currency administration. It

.35.
is in the financial field that the sentiment against any form of
oligarchy is particularly and justifiably deeply rooted in the American nature.
I have, therefore, orclosed that the Open Market Committee
^ould continue as it has since 1950 to include in its membership
a

representative of each of the twelve Federal Reserve banks, in

0r

der that ever;/ region may continue to have equal representation.
No gofe£uqrds
The plan adopted by the House offers no safeguard against hasty

°r Ul~advisod action by the Federal Reserve Board itself when it
act

s on its own initiative.
This seems to me to be a very serious defect in the House plan.

ction looking to a "loosening up" or to a "tightening up" of the
country's money supply ought to be undertaken
hdication of its advisability.

only

upon pretty clear

To adjust correctly the amount of

country's monetary supply to its economic needs is a far from
uln

^ple problem. Histakes are costly and sometimes disastrous; wit-

nea

s the effect of the fluctuating course of Federal Reserve policy

from 1927 to 1929.
Credit is an organism and interference with its workings at any
p

°int, unless interference is necessary, may occasion unexpected re°ns elsewhere in the organism which will sooner or later manifest

the

^selves in disturbance of function. At times over-stimulation may
lead j speculative excesses and their consequences. At other times,

36.
an

insufficient supply of money may work painful and disastrous in-

dustrial restriction.
X propose that, when the Federal Reserve Board assumes the
initiative, and, therefore, the sole responsibility, in the exercise
the open-market authority of the Federal Reserve System, its action shall require more than a mere majority vote of the Board to
become effective. Following the; precedent already established in
the Federal Reserve Act in analogous matters, I propose that, whatbe the number of the members of the Board, such action shall
Squire the affirmative vote of one more than a majority of the
Board's entire membership.

In the present B0ard of eight members,

•S would require six votes. If the Board were reduced to five members

> the requirement would be four votes.
As a further safeguard to insure well-considered action, I have

Proposed that the Board be required to make a contemporaneous record
n

°t only of every vote taken on the subject of open-market policy but

a

lso of the reasons underlying its action. Furthermore, I propose

that the contemporaneous record both of the vote and of the reasons
b

Published annually by the Board in its report to Congress,
strengthening against pblitical influence
it does nothing to strengthen the position of the Board against
impact of external influence, which has been characterized in
Urr

ent discussions as political influence but which may also take
form of the special influence of financial interests or groups.

When all is said and done, the plain truth is that men are the
stuff of which Government is made. No statute however ingeniously
contrived can protect the country completely against the consequences
the exercise of administrative discretion weakly conceived and
weakly carried out. The law can, however, provide conditions favorable t0 thc G x e r c i s e of its

° y*
a

best intelligence by an administrative

Concentration of an inescapable responsibility in the hands of

body composed of men of character and high purpose can do much to

Sicken its intelligence, strengthen its resolution and cultivate its
capacity for wise selective judgment and the habit of prompt and decisivo action.
•'hat then can the new banking legislation do to improve the
Slt

-uation of the Federal Reserve Board and insure a nore competent

Performance by the Federal Reserve System in the field of open-market
Poj.iCy should , h e Federal Reserve Board be invested with ultimate
u

thority and responsibility?
%

answer is to make the Board master in its own house by giving

it( Q

n assured position of complete independence both in law and in

faCt

"

S

° far

as can be

an

-y f o r m

done by statute law, it should be immunized

interference, pressure or influence, be its

s

°urce financial or political.
Tn order to give the Federal Reserve Board a position as nearly
mJI,Uri0 f r o m suc
th

h influences as possible, I have proposed that members

e Board should, if not immediately then in due course, be

58.
appointed for longer terms of service, that they should not be removable except by impeachment, that members reaching the age of seventy
should be given an allowance on voluntary retirement, that the title
the Federal Reserve Board should be changed to the Board of Governors
the Federal Reserve System, and finally that the executive head of
tne B o Q r d

should be a chairman elected by the Board instead of a

Governor appointed by the President.
If all this were done, I doubt that there is any place or body
where the all-important open-market authority and responsibility of
the Federal Reserve System could be lodged with a surer prospect of
c

°mpetent exorcise than with the Board of Governors of the Federal Re-

serve System, but I would not look with favor upon the concentration
of

this great power in the hands of the Federal Reserve Board unless
until the Board is given a position of unassailable independence.

^

.^attainable .objective

One further objection lies against the bill as passed by the
fj
Us

e of Representatives.

It is one which is intimately related to

the exercise of the open-market authority. Specifically I refer to
the

objective of Federal Reserve policy laid done in the House bill,

*hich

reads as follows

"It shall be the duty of the Federal Reserve Board to
exorcise such powers as it possesses in such manner as to
promote conditions conducive to business stability and to
mitigate by its influence unstabi.liz.ing fluctuations in the
general level of production, trade, prices, and employment,
•3o fa.r as may bo possible within the scope of monetary action
and credit administration."

.39.
To analyze and discuss this proposal at all adequately would
unduly prolong this paper. But it is my belief that this objective,
011 t h e o n e

hand, undertakes too much and, on the other, provides far

too many loopholes or excuses in case the Reserve System, fails to
achieve the objective.
That the Federal Reserve Act must contain an objective and
Particularly an objective for the guidance of the open-market policy
of

the System cannot be gainsaid. Such a definition is essential,

but

it should confine itself to the probably useful and , attainable.

For

this purpose I have proposed a guide or principle to read as fol-

lows :
"The time, character and volume of all Open-Market operations of zha Federal Reserve System under Section 14 of this
Act shall be governed with a view to supporting and re-enforcing
tiie credit and discount policies of the Federal Reserve System
when this may be necessary in order to aid in the establishment
and maintenance of sound banking, credit, financial and economic
conditions,"
This would subordinate the open-market policy of the Federal

©serve System to its general credit and discount policies, to be
de t
ermined by considerations of national economic welfare. What
is

important, it would further provide an additional safeguard,

SO fn., ,n
at least as statute law can do it, against subordination of
national economic interests as conceived and interpreted by the
e

deral Reserve Board to the fiscal needs of the Treasury or to. the

c01

itical wishes of the administration in power at the time. .

.40.
AGAINST COMPROMISE PLANS
There is little or nothing to be said in my opinion in favor of
fV
e many proposals that have been made for the establishment of a new
within the Federal Reserve System to be vested with authority and
Responsibility for open-market policy, discount rates and changes of
reserve requirements. All of these plans contemplate a body composed
of >-•
representatives of the Federal Reserve banks and of the Federal
Re
serve Board.
of

representation accorded to Reserve banks, running from a minimum

of +
and

They differ from one another mainly in the proportion

wo bank governors and three- Board members to five bank governors
all of the eight members of the Federal Reserve Board.
Overlooking differences in detail, these plans are all based upon

°mPromise. And the compromise grows out of the distrust with which the
^tending interests with respect to banking legislation regard one
Tile

banker and those who go along with him distrust government

°htrol because they fear it will in the end prove to be political control
On the other side are those who distrust banking and financial
°ntrol because they feel that it will in the future, as has been so
tori

demonstrated in the past, be animated by short-sighted and selfish

"^derations.
join such discordant elements in the same body in the expectation
the hope that out of their differences will come a useful format!
of national monetary ana credit policies is to ignore the lessons
of

>
0

experience which has been recited above.

Such a boay would be

§ in the singleness of ourpose and undivided devotion to a public
Which should be the principal characteristic of any body to which

I

41.
18 e n t r u s t e d

important power affecting the economic welfare of the

nation. Being born of a feeding of distrust between two conflicting
f0rCos
of

1 1 v;oulfJ

>

tund to perpetrate and accentuate such distrust in all

its proceedings.

I!

A house, divided against itself cannot stand."

-he radical defect in these proposals is that they give bankers
Potential control without legal responsibility, through the device of
Putting them in a position where they could control the decisions of the
Committee by obtaining the support of one or at most two members of the
Board.
^iere is nothing not about the proposal. The Aldrich plan contemP l a t e U a ct!n

tral banking system of the bankers, by the bankers, for the

to

^nkort. They would have controlled it completely. When President Wil8

° n A n s i s t e d uP°n the creation of the Federal Reserve Board, a public
body
supervise and direct the affairs of the regional banking system
ontemplated by the federal Reserve Act, the bankers sought representaion
°n the Board. They obtained much support for this idea in Congress.
The j
e was

carried to the White House, where President Wilson promptly

-it adversely to the bankers.
was twenty-two years ago, when the Federal Reserve System was
8t

created and there hau been no experience demonstrating the

Power ro r

£oocJ £-nd for evil that can be exercised by Federal Reserve credit
Ti

h

,

,

.

,

" 1 L wouia indeed be an ironic reversal and a queer "new deal"
if th-y ground that was won during the birth ef the Federal Reserve System
nov; be sacrificed by admitting banker representation to the body
wil

ich is entrusted the determination of national credit and monetary

POll

Ci03.

.42.
SUMMARY
1. In view of current discussions and controversies in connection
the Banking Bill of 1955, it is worthwhile to review the experience
0f

Federal Reserve System in 1927 to 1929 and see what light it

s

heds on the- desirability of proposed amendments.
2. This is particularly opportune because many commentators, in-

cluding the New York Times in an editorial on June 2, 1935, refer to the
^stem's experience in those years as proof that the Federal Reserve
Sard's judgment is not so good as that of the Federal Reserve banks
^

that the mistakes the System committed during that period were due

to

the Federal Reserve Board.
3. Briefly stated, the facts in the matter are:
(a) as to 1927, that in that year the; System adopted a policy

of

ea

sing credit initiated by the Federal Reserve Bank of New York and

hat the reduction by the federal Reserve Board of the discount rate of
th

federal Reserve Bank of Chicago was in pursuance of this policy;
(b) as to 1923, that the Federal Reserve hanks, after making
tempts to curb speculation in the early part of the year, took no
ac

tion to check speculation from July 1928 until February 14, 1929;
(c) as to 1929, that in that year the Federal Reserve Board
\ the lead in actively intervening in the situation for the purpose

of
c

h<3cking speculative expansion, and that it was not until after the
had taken the lead that the Reserve banks proposed advances in

^count rates; and
(d) that ciff orenoes between the Kcserve banks and the Federal
Serve

te.

Board in 1929 wore as to the best method for checking specula-

and riot as to the desirability of action.

43.
4. It is admitted that the Board shares the responsibility for any
aC

tion or inaction during the period under consideration, but under the
and the tradition which has grown up in the Federal Reserve System

fi
e

initiative in credit policy and, therefore, the primary responsibility

re

sts with the Federal Reserve banks, while the Federal Reserve Board
-Ky approves or disapproves of their recommendations and its responsi-

b l y , therefore, is secondary.
5. The reason for the easing credit policy adopted in 1927 was
tlux-

t there was a recession in business, and that weakness in the foreign
a

hges with the approach of the heavy export season in the autumn might

e

Placed a serious burden on those countries which had recently return0

Were

the gold standard, like Great Britain, and other countries which
Preparing to do so.
A

•

The policy adopted in 1927 was successful when judged by the

hat business activity in this country was revived and that the flow

Of

gold was reversed and the pressure on the exchanges relieved.
7

*

The 1927 policy was conceived and formulated at the Federal

V( B a n k

'

of New York by its late Governor Benjamin Strong.

While the policy was successful in the ways already stated, it
had fUr>+,
^x-her consequences in that it gave another impetus to speculative
*ctivitv
y which by that time had gained an enormous momentum.
9

mi

•

Tae policy of ease was reversed late in 1927 and a policy of
was

carried on through the first half of 1928, first, by oer-

fc gold exports to exert their normal tightening influence on the
» secondly, by the sale by the Federal Reserve System of v400,000,000

.44.
01 U n i t G d

States Government securities an;, thirdly, by advances in dis-

count rates at the Federal Reserve banks from 3 1/2 to 5 percent in eight
to 4 1/2 percent in the other four.

bunkR a n d

10

'

Speculation, however, had gone so far by that time and the pull

for
ank and

°ther funds was so great that these measures were nut suffi-

C i e n b tc

> check expansion.
• In the latter half of 1923 nothing further was done to arrest
specul»+ •
31

'lon>

in f

^ct the situation was eased by the acquisition of a large

°lumet of acceptances by the Federal Reserve banks which enabled member
biink
a
reduce their indebtedness to the Reserve banks. This was due to
Unvvxi "i •
- ingness to tighten credit at a time when crops are marketed. The
' i a l Reserve banks made no proposals to the Federal Reserve Board for
furth
° r restraint of speculation during that period, and the Federal RerV

° Board
12

•

did

not at that time take the lead in the matter.

In February 1929 the Board actively intervened by issuing a

to front
'' n"t in which it proposed that member banks which were increasing
the^ i
oans on

securities should not be permitted to receive accommodation

u
Resorve banks. This was the policy of "direct action."
13 • federal
Subsequent to this intervention by the Board, the Federal Re-

arikq proposed discount rate advances as their remedy for the situaTh.
nG Roard

refused to appr >ve these advances on the ground that ad-

Vftll

Ces

of

f
UJ

- i -.ciunt to have an influence on thu existing speculative situaWe"ill *h a v o t^
Su high as to disrupt the commercial rate structure
^
country, and also because it believed th<-t the policy of direct
a

s more effective in the circumstances and more flexible.

I

45.
14. The Board's policy was successful in reducing the volume of
brokers' loans, in arresting the advance in security prices, and in
checking the growth of speculation.
15, At the approach of the end of the fiscal year heavy demands
f r

° financing by leading industrial corporations made it clear that the

continuation of the Board's policy of direct action might result in
Mediate catastrophe. For this reason, and because it recognized that
the

stock market at that time had entered a phase where its collapse of

its

own weight was merely a matter of time, the Board decided to suspend
H

Pressure.

It felt that it had become the immediate duty of the

°ral Reserve System to prepare itself for meeting the imminent shock
^

to

business and credit.
Lessons from this experience and my views regarding pending banking
Sislation as related to this experience may be summarized as follows:

16. Final authority and continuous responsibility for national
credit
.
Policies should be concentrated in a single, impartial, disinterested Public body having a national viewpoint and owing undivided allegiance
to t h e

general public interest.

17

•

The plan adopted by the House of Representatives, which would

n

°entrate such authority and responsibility in the Federal Reserve Board

but

u

ld require the Board to consult and advise with an Open Market
consisting of five representatives of the Federal Reserve banks,

ho
®Uch to commend it; but it has the following deficiencies:
(a) The representatives of the Reserve banks would have merely
isory status and, therefore, not the same feeling of responsibility

^tt advi

they would have if they wore given more ziuthority.

.46.
(b) It provides for only limited representation of the Federal
Reserve banks through a membership of only five members.
(c) It. offers no safeguard against hasty or ill-advised action
b y t h o i?

ederal Reserve Board itself when it acts on its own initiative.
(cl) It does nothing to strengthen the position of the Board

a

2ainst the impact of external influence, which has been characterized
in
current discussions as "political influence" but which may also take

th0^

form of special influence by financial interests or groups.
(e) The statement of objectives in the House bill undertakes

to

much and, in recognition of this fact, provides for too many excuses

a

0I fai1

"

-ure to achieve the objective.

18

•

The plan which I have proposed would correct these deficiencies

y the following means:
(a) It would give the Open Market Committee authority and
-"Ponsibility fur the initiation of open-market policies subject to
v

> mortification, and determination by the Federal Reserve Board;

but at +h
Lile

sane tirc-j it would impose continuous responsibility upon the

•i deserve Board by giving it also the authority to initiate policies.
(b) It would preserve the existing arrangement under which every
^er&i n
Reserve bank is represented on tho Open Market Committee, thus
surAn
ing considerati »n of the views of all parts of the country.
(c) It would require that, when the Federal Reserve Board acts
it*

° W n initiative, it should do so only on the affirmative vote of
a
t l^.o-j.
one more than a majority of the Boax-d's entire membership, and
require the Board to maintain a contemporaneous record of all actions

47.
t&ken

and the reasons therefor and to publish the same in its

annual reports.
(d) It would strengthen the independence of the Federal Reserve
a
rc

~

Providing that Board members should be appointed for longer terms

"they should not be removable except by impeachment, that members
Aching the age of 70 should be given an allowance on voluntary retirethat the title uf the Federal Reserve Board should be changed to
"Board of Governors of the Federal Reserve System," and that the
QXecui--* -L.
&J

-ve head of the Board should be a chairman elected by the Board

ns

tead of a Governor appointed by the President.
(e) It would subordinate open-market operations to the position
supporting and reenforcing the credit and discount policies of the
Reserve System when it is necessary to aid in the establishment
•i-ntenance of sound banking, credit, financial and economic conditions

authori + To adopt any of the suggested compromises which would place
and responsibility for national credit policies in a newly
Seated

v, v .
» hybrid body consisting of some or all of the members of the

era
and an
number of Reserve
bank governors
Would l
be Reserve
to sow Board
the seeds
of almost
discord equal
and impotence,
to sacrifice
an imPQrtan.v

° Principle preserved in the original Federal Reserve Act by Presi^

WUson.