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American Bankers Association (2)
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324359042
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American Bankers Association (2)
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Arthur F. Burns Papers
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Federal Reserve System. (1913 - )
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The original documents are located in Box B1, folder "American Bankers Association (2)" of the Arthur F. Burns Papers at the Gerald R. Ford Presidential Library. Copyright Notice The copyright law of the United States (Title 17, United States Code) governs the making of photocopies or other reproductions of copyrighted material. Gerald R. Ford donated to the United States of America his copyrights in all of his unpublished writings in National Archives collections. Works prepared by U.S. Government employees as part of their official duties are in the public domain. The copyrights to materials written by other individuals or organizations are presumed to remain with them. If you think any of the information displayed in the PDF is subject to a valid copyright claim, please contact the Gerald R. Ford Presidential Library. THE AMERICAN BANKERS ASSOCIATION 815 CONNECTICUT AVENUE, N. W., WASHINGTON, D.C. 20006 WILLIS W. ALEXANDER EXECUTIVE VICE PRESIDENT May 1, 1970 The Honorable Arthur Burns Chairman Board of Governors of the Federal Reserve System Washington, D.C. 20551 Dear Dr. Burns: The 1970 A.B.A. Monetary Conference plans are in final form. We are pleased that you will address the meeting at the Monday noon luncheon and hope you will find it an interesting and provocative session. One significant change has taken place in arrangements. Earlier, we had indicated that only bus transportation was available from Washington at 1:00 p.m. on Sunday, May 17 to The Homestead and returning on Wednesday, May 20. Because of numerous requests we have now augmented our transportation to include charter flights for those who would so desire. The aircraft to be used are Piedmont Airlines' two engine prop-jet Martin 404s and each will accommodate 44 passengers. We will use as many planes as are necessary to transport participants. For the air transportation, limou- sines will depart from the Madison Hotel at 1:30 p.m. for Washington National Airport and the one hour flight to Hot Springs. The flights will depart National Airport at 2:00 p.m. with arrival at The Homestead to be shortly after 3:00 p.m. Returning on Wednesday following the Conference, limousines will de- part The Homestead at 3:30 p.m., with arrival at Washington National scheduled for 5:30 p.m. We will be pleased to arrange your transportation from Washington to Hot Springs if we can be of assistance. We realize your schedule is extremely full, and while we would certainly like to have you with us for as long a time as possible, we do understand that your plans are to return to Washington on Monday. We have suggested the above transportation arrangements in the event you may desire to go to Hot Springs on Sunday rather than Monday morning as your secretary has indicated were your preliminary plans. We will look forward to receiving your travel plans when they are formulated. Enclosed is a preliminary copy of the Conference Program, along with a list of the expected attendees. FORD i LIBRARY GERALD THE AMERICAN BANKERS ASSOCIATION CONTINUING OUR LETTER OF May 1, 1970 SHEET No. 2 Again, we look forward to your participation in the Seventeenth Monetary Conference. Please let us know if we may be of any further assistance to you. Sincerely, Willi W. alexander Encl. FORD & LIBRARY 938670 QUESTIONNAIRE #2 To facilitate transportation planning by bus or charter aircraft to and from The Homestead, please complete this questionnaire and return it as soon as possible. 1. My transportation is arranged and I do not desire to utilize either the special charter aircraft or bus transportation. 2. From Washington to Hot Springs on May 17: I would like to travel by the charter flight. I would like to travel by bus. 3. From Hot Springs to Washington on May 20: I would like to travel by the charter flight. I would like to travel by bus. 4. This changes my requirements for a reservation at the Madison Hotel before and/or after the Conference as follows: (Name) (Organization) (Address) Please return completed questionnaire to: Mr. Roy W. Terwilliger The American Bankers Association 815 Connecticut Avenue N.W. Washington, D.C. 20006 (Please return one copy of this questionnaire and keep the duplicate for your file). FORD & LIBRARY GERALD QUESTIONNAIRE #2 To facilitate transportation planning by bus or charter aircraft to and from The Homestead, please complete this questionnaire and return it as soon as possible. 1. My transportation is arranged and I do not desire to utilize either the special charter aircraft or bus transportation. 2. From Washington to Hot Springs on May 17: I would like to travel by the charter flight. I would like to travel by bus. 3. From Hot Springs to Washington on May 20: I would like to travel by the charter flight. I would like to travel by bus. 4. This changes my requirements for a reservation at the Madison Hotel before and/or after the Conference as follows: (Name) (Organization) (Address) Please return completed questionnaire to: Mr. Roy W. Terwilliger The American Bankers Association 815 Connecticut Avenue N.W. Washington, D.C. 20006 (Please return one copy of this questionnaire and keep the duplicate for your file). FORD & LIBRARY GERALD CONFERENCE SCHEDULE SUNDAY, MAY 17 12 Noon Luncheon at the Madison Hotel, Washington 1:00 p.m. Buses leave the Madison Hotel 1:30 p.m. Limousines leave the Madison Hotel for Washington National Airport 6:45 p.m.- Chairman's reception ...... Crystal Room 7:45 p.m. 7:45 p.m. Dinner Empire Room Business Session for International Banking Conference MONDAY, MAY 18 9:00 a.m.- Session I Commonwealth Room 12 Noon Coffee break: 10:00 a.m. 12 Noon- Social half hour Crystal Room 12:30 p.m. 12:30 p.m.- Luncheon Empire Room 1:30 p.m. 2:30 p.m.- Session II Commonwealth Room 5:00 p.m. Business Session for International Banking Conference 6:00 p.m.- Social hour Crystal Room 7:00 p.m. 7:00 p.m.- Dinner Empire Room 8:00 p.m. FORD i LIBRARY GERALD CONFERENCE SCHEDULE TUESDAY, MAY 19 9:00 a.m.- Session III Commonwealth Room 12 Noon Coffee break: 10:00 a.m. 12 Noon- Social half hour Crystal Room 12:30 p.m. 12:30 p.m.- Luncheon, Empire Room 1:30 p.m. 2:00 p.m.- Session IV. Commonwealth Room 4:30 p.m. Business Session for International Banking Conference 6:00 p.m.- Social hour Crystal Room 7:00 p.m. 7:00 p.m.- Dinner Empire Room 8:00 p.m. 8:15 p.m. Session V Empire Room WEDNESDAY, MAY 20 9:00 a.m.- Session VI Empire Room 12 Noon Coffee break: 10:00 a.m. 12 Noon- Social half hour Crystal Room 12:30 p.m. 12:30 p.m.- Luncheon Commonwealth Room 1:30 p.m. 3:00 p.m. Buses leave The Homestead 3:30 p.m. Limousines leave The Homestead for the airport FORD & LIBRARY GERALD CONFERENCE PROGRAM Sunday Welcoming Remarks and May 17 Opening Comments Nat S. Rogers, President, The American Bankers Association, and President, First City National Bank William H. Moore, Chairman of the Monetary Conference, and Chairman, Bankers Trust Company BUSINESS SESSION FOR INTERNATIONAL BANKING CONFERENCE SESSION I THE BATTLE AGAINST INFLATION Monday CHAIRMAN: May 18 Frederick G. Larkin, Jr., Chairman of the 9:00 a.m. Board, Security Pacific National Bank Commonwealth Room SPEAKERS: Paul W. McCracken, Chairman, Council of Economic Advisers Robert P. Mayo, Director, Bureau of the Budget Charls E. Walker, Under Secretary of the Treasury Andrew F. Brimmer, Member of the Board of Governors of the Federal Reserve System Walter Heller, Professor of Economics, University of Minnesota John Young, Chairman of the Prices and Incomes Commission, Canada FORD LIBRARY & GERALD CONFERENCE PROGRAM Luncheon REMARKS: Monday Arthur F. Burns, Chairman, Board of Governors May 18 of the Federal Reserve System 12:30 p.m. Empire Room SESSION II THE INTERNATIONAL MONETARY SITUATION Monday May 18 CHAIRMAN: 2:30 p.m. Louis Camu, Chairman, Banque de Bruxelles Commonwealth Room SPEAKERS: J. J. Polak, Economic Counselor, International Monetary Fund Peter B. Kenen, Provost, Columbia University Louis Camu, Chairman, Banque de Bruxelles (speaker to be announced) Wolfgang Schmitz, President, Oesterreichische Nationalbank 5:00 p.m. BUSINESS SESSION FOR INTERNATIONAL BANKING CONFERENCE FORD & LIBRARY GERALD CONFERENCE PROGRAM SESSION III CAN BALANCE OF PAYMENT PROBLEMS BE SOLVED? Tuesday May 19 CHAIRMAN: 9:00 a.m. Emmett G. Solomon, Chairman of the Board, Crocker-Citizens National Bank Commonwealth Room SPEAKERS: Sir Douglas Allen, Permanent Secretary to the Treasury Guenther Schleiminger, German Executive Director, International Monetary Fund Andre de Lattre, Deputy Governor, Banque de France Yusuke Kashiwagi, Vice Minister of Finance for International Affairs, Ministry of Finance, Japan Paul A. Volcker, Under Secretary of the Treasury for Monetary Affairs INTERROGATORS: Helmuth Cammann, General Manager, Bundesverband deutscher Banken C. F. Karsten, Managing Director, Amsterdam- Rotterdam Bank, N.W. Jean Richard, Directeur General Adjoint, Societe General Sir Eric Roll, K.C.M.G., C.B., Executive Director, S. G. Warburg & Co. Ltd. F. W. Schulthess, Chairman of the Board, Swiss Credit Bank Marc Wallenberg, Jr., President, Stockholms Enskilda Bank FORD & LIBRARY GERALD CONFERENCE PROGRAM SESSION IV IMPACT OF CREDIT CONTROLS ON COMMERCIAL BANKS Tuesday May 19 CHAIRMAN: 2:00 p.m. Gaylord A. Freeman, Jr., Chairman of the Board and Chief Executive Officer, First National Commonwealth Room Bank of Chicago SPEAKERS: Donald P. Jacobs, Professor of Finance, Graduate School of Management, Northwestern University Wesley Lindow, Executive Vice President and Secretary, Irving Trust Company K. A. Randall, Vice Chairman of the Board, United Virginia Bankshares Inc. Rex J. Morthland, President, The Peoples Bank and Trust Company Eric John Newnham Warburton, Vice Chairman, Lloyds Bank Limited 4:30 p.m. BUSINESS SESSION FOR INTERNATIONAL BANKING CONFERENCE SESSION V UNANSWERED QUESTIONS (An open session for questions Tuesday and discussion) May 19 8:15 p.m. CHAIRMAN: Roy L. Reierson, Senior Vice President and Chief Empire Room Economist, Bankers Trust Company FORD & GERALD LIBRARY CONFERENCE PROGRAM SESSION VI CHALLENGES FACING CENTRAL BANKERS Wednesday CHAIRMAN: May 20 George W. Mitchell, Member, Board of 9:00 a.m. Governors of the Federal Reserve System Empire Room SPEAKERS: C. Jeremy Morse, Executive Director, Bank of England Andre de Lattre, Deputy Governor, Banque de France Karl Klasen, President, Beutsche Bundesbank Shiro Inoue, Executive Director, The Bank of Japan L. Rasminsky, Governor, Bank of Canada INTERROGATORS: Geoffrey Bell, Assistant to the Chairman, J. Henry Schroder Wagg, Ltd., New York Robert Dhom, General Manager, Commerzbank AG Gabriel Hauge, President, Manufactuers Hanover Trust Company Samuel Schweizer, Chairman of the Board, Swiss Bank Corporation Lars-Erik Thunholm, Chief Managing Director, Skandinaviska Banken FAREWELL SPEAKER: LUNCHEON David M. Kennedy, Secretary of the Treasury Wednesday May 20 12:30 p.m. Commonwealth Room FORD & GERALD LIBRARY PARTICIPANTS FOR THE 1970 MONETARY CONFERENCE Willis W. Alexander Executive Vice President, The American Bankers Association Sir Douglas Allen KCB Permanent Secretary, HM Treasury, London C. B. Andersen Chief General Manager, Kjøbenhavns Handelsbank, Copenhagen Thomas R. Atkinson Deputy Manager, The American Bankers Association Geoffrey Bell Assistant to the Chairman, J. Henry Schroder Wagg, Ltd., New York T.H. Bevan Vice Chairman, Barclays Bank Limited, London H. Bizot Chairman, Banque Nationale de Paris Carlo Bombieri Managing Director, Banca Commerciale Italiana, Milan Andrew F. Brimmer Member, Board of Governors of the Federal Reserve System George Brosa General Manager, Banco Espanol de Credito, Madrid George H. Brown, Jr. Chairman of the Board, Girard Trust Bank, Philadelphia Arthur F. Burns Chairman, Board of Governors of the Federal Reserve System FORD & LIBRARY - 2 - Helmuth Cammann General Manager, Bundesverband deutscher Banken William B. Camp Comptroller of the Currency Louis Camu Chairman, Banque de Bruxelles s.a., Brussels Maxwell Carlson President, National Bank of Commerce of Seattle Edward L. Carpenter Chairman and Chief Executive, Central National Bank of Cleveland William A. Carpenter President, Whitney National Bank of New Orleans A. W. Clausen President, Bank of America N.T. & S.A., San Francisco Fernand J. Collin Chairman of the Board, Kredietbank N.V., Brussels Richard P. Cooley President, Wells Fargo Bank, San Francisco J. Dewey Daane Member, Board of Governors of the Federal Reserve System William L. Day Chairman, First Pennsylvania Bank, Philadelphia Charles de Bretteville Chairman and Chief Executive Officer, The Bank of California, San Francisco Robert Dhom General Manager, Commerzbank AG., Frankfurt FORD, & LIBRARY GERALD - 3 - A.F.J. Dijkgraaf Member of the Presidium, Algemene Bank Nederland N.V., Amsterdam G. Morris Dorrance, Jr. President, The Philadelphia National Bank George S. Eccles President, First Security Bank of Utah N.A., Salt Lake City Manuel R. Espirito Santo Silva Chairman, Banco Espirito Santo e Comercial de Lisboa, Lisbon Eric 0. Faulkner Chairman, Lloyds Bank Limited, London Alberto Ferrari Managing Director, Banca Nazionale del Lavoro, Rome John Fox Chairman, Mercantile Trust Company, N.A., St. Louis Gaylord A. Freeman, Jr. Chairman of the Board, The First National Bank of Chicago Douglas R. Fuller President, The Northern Trust Company, Chicago Merle E. Gilliand President, Pittsburgh National Bank Harold V. Gleason President, Franklin National Bank, New York Donald M. Graham Chairman, Continental Illinois National Bank and Trust Company of Chicago G. Arnold Hart Chairman and Chief Executive Officer, Bank of Montreal FORD is LIBRARY GERALD - 4 - Gabriel Hauge President, Manufacturers Hanover Trust Company, New York Alfred Hayes President, Federal Reserve Bank of New York Walter W. Heller Regents' Professor of Economics, University of Minnesota, Minneapolis James P. Hickok Chairman, First National Bank of St. Louis Richard D. Hill President, The First National Bank of Boston Walter E. Hoadley Executive Vice President and Chief Economist, Bank of America N.T. & S.A., San Francisco Shiro Inoue Executive Director, The Bank of Japan, Tokyo Donald P. Jacobs Professor of Finance, Graduate School of Management, Northwestern University William M. Jenkins Chairman, Seattle-First National Bank Lewellyn A. Jennings Chairman of the Board and Chief Executive Officer, The Riggs National Bank of Washington, D.C. Edwin S. Jones President, First National Bank in St. Louis C. F. Karsten Managing Director, Amsterdam-Rotterdam Bank N.V., Amsterdam FORD i LIBRARY GERALD - 5 - Yusuke Kashiwagi Vice Minister of Finance for International Affairs, Ministry of Finance, Japan George J. Kelly Deputy Manager, The American Bankers Association Peter B. Kenen Provost, Columbia University David M. Kennedy Secretary of the Treasury Frederick H. Kingsbury, Jr. Partner, Brown Brothers Harriman & Co., New York Karl Klasen President, Deutche Bundesbank, Frankfurt Paul Krebs Assistant General Manager, Deutsche Bank AG., Frankfurt J. Howard Laeri Vice Chairman, First National City Bank, New York Allen T. Lambert Chairman of the Board and President, The Toronto-Dominion Bank Frederick G. Larkin, Jr. Chairman of the Board, Security Pacific National Bank, Los Angeles Andre de Lattre Deputy Governor, Banque de France, Paris Wesley Lindow Executive Vice President and Secretary, Irving Trust Company, New York Lawrence H. Martin Chairman of the Board, The National Shawmut Bank, Boston FORD & LIBRARY GERALD - 6 - Ichiro Matsudaira Deputy President, The Bank of Tokyo, Ltd. John A. Mayer Chairman of the Board, Mellon National Bank and Trust Company, Pittsburgh Robert P. Mayo Director, Bureau of the Budget Paul W. McCracken Chairman, Council of Economic Advisers W. Earle McLaughlin Chairman and President, The Royal Bank of Canada, Montreal Charles R. McNeill Director of the Washington Office, The American Bankers Association Jacques Merlin ' Chairman, Credit Commercial de France, Paris John M. Meyer, Jr. Chairman of the Board, Morgan Guaranty Trust Company of New York Derek Mitchell Economic Minister, British Embassy, Washington George W. Mitchell Member, Board of Governors of the Federal Reserve System William H. Moore Chairman, Bankers Trust Company, New York John A. Moorhead Chairman of the Board, Northwestern National Bank of Minneapolis C. Jeremy Morse Executive Director, Bank of England, London FORD & LIBRARY GERALD - 7 - Rex J. Morthland President, The Peoples Bank and Trust Company, Selma, Alabama Rokuro Mukasa Managing Director, The Sumitomo Bank, Ltd., Osaka William F. Murray President, Harris Trust and Savings Bank, Chicago Philip H. Nason President, The First National Bank of Saint Paul Mariano Navarro-Rubio N Governor, Banco de Espana, Madrid Crocker Nevin Chairman and President, Marine Midland Grace Trust Company of New York F. William Nicks Chairman of the Board and President, The Bank of Nova Scotia, Toronto Herbert P. Patterson President, The Chase Manhattan Bank, N.A., New York Leslie C. Peacock President, Crocker-Citizens National Bank, San Francisco Raymond T. Perring Chairman, Detroit Bank and Trust Company Howard C. Petersen Chairman, The Fidelity Bank, Philadelphia William E. Petersen President, Irving Trust Company, New York J. G. Phillips Governor, Reserve Bank of Australia, Sydney FORD is LIBRARY GERALD - 8 - J.J. Polak Economic Counsellor, International Monetary Fund W. Dewey Presley President, First National Bank in Dallas Herbert V. Prochnow Honorary Director and Former President, The First National Bank of Chicago W. G. Pullen Chairman, The Chartered Bank, London K. A. Randall Vice Chairman of the Board, United Virginia Bankshares, Inc., Richmond L. Rasminsky Governor, Bank of Canada, Ottawa Addison H. Reese Chairman of Board, North Carolina National Bank, Charlotte Roy L. Reierson Senior Vice President and Chief Economist, Bankers Trust Company, New York Peter Reimpell Deputy Managing Director, Vorstandsmitglied Der Bayerischen Vereinbank, Munich William S. Renchard Chairman, Chemical Bank, New York Jean Richard I Directeur General Adjoint, Societe Generale, Paris Dean E. Richardson President, Manufacturers National Bank of Detroit FORDO & LIBRARY GERALD - 9 - Nat S. Rogers President, The American Bankers Association, and President, First City National Bank, Houston Sir Eric Roll, K.C.M.G., C.B. Executive Director, S. G. Warburg & Co. Ltd., London Guenther Schleiminger German Executive Director, International Monetary Fund Wolfgang Schmitz Chairman and President, Oesterreichische Nationalbank, Vienna F. W. Schulthess Chairman of the Board, Swiss Credit Bank, Zurich Samuel Schweizer Chairman of the Board, Swiss Bank Corporation, Basle Lyman E. Seely Executive Vice President, First National Bank of Oregon, Portland Edward D. Smith Chairman and President, The First National Bank of Atlanta Emmett G. Solomon Chairman of the Board, Crocker-Citizens National Bank, San Francisco Clifford C. Sommer Vice President, The American Bankers Association, and President, Security Bank and Trust Company, Owatonna, Minnesota S. O. Sørensen General Manager, Den Danske Landmansbank, Copenhagen Beryl W. Sprinkel Senior Vice President and Economist, Harris Trust and Savings Bank, Chicago FORD is 108 RARV - 10 - LeRoy B. Staver President, United States National Bank of Oregon, Portland A. De V. Stewart-Richardson Senior Deputy General Manager, Bank of New South Wales, Sydney Howard J. Stoddard Chairman, Michigan National Bank, Lansing Clyde L. Stutts Treasurer, The American Bankers Association, and President, Union Trust Company, Shelby, North Carolina Robert M. Surdam President, National Bank of Detroit Roy W. Terwilliger Deputy Manager, The American Bankers Association Lars-Erik Thunholm Chief Managing Director, Skandinaviska Banken, Stockholm Heinrich Treichl Member of the Managing Board, Creditanstalt-Bankverein, Vienna Matti Virkkunen Chief General Manager, Kansallis-Osake-Pankki, Helsinki Paul A. Volcker Under Secretary of the Treasury for Monetary Affairs Harry J. Volk Chairman, Union Bank, Los Angeles J. Page R. Wadsworth Vice Chairman, Canadian Imperial Bank of Commerce, Montreal FORD j LIBRARY 0ERALD - 11 - Charls E. Walker Under Secretary of the Treasury Marc Wallenberg, Jr. President, Stockholms Enskilda Bank, Stockholm Eric John Newnham Warburton Vice Chairman, Lloyds Bank Limited, London John F. Watlington, Jr. President, Wachovia Bank and Trust Company N.A., Winston-Salem Frank Wille Chairman, Federal Deposit Insurance Corporation, Washington John H. Wills Senior Vice President and Chief Economist, The Northern Trust Company, Chicago Samuel H. Woolley Chairman, The Bank of New York Paul I. Wren Chairman of Board and Chief Executive Officer, Old Colony Trust Company, Boston Walter B. Wriston Chairman, First National City Bank, New York Kenzo Yamamoto Agent, Fuji Bank, New York Agency John Young Chairman, Prices and Incomes Commission of Canada, Ottawa GERALD ini) R. FORD BH-14 THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N.Y. 10016 NAT S. ROGERS PRESIDENT FIRST CITY NATIONAL BANK HOUSTON, TEXAS 77001 May 27, 1970 The Honorable Arthur F. Burns Chairman Board of Governors Federal Reserve System Washington, D. C. 20551 Dear Mr. Chairman: The American Bankers Association, through the activities of its Agricultural and Rural Affairs Committee, has encouraged rural banks to stay in the forefront as full financial service centers in their communities. A considerable part of this effort has been directed toward a better understanding of the various sources of funds available to banks in rural areas where often seasonal or even longer-term short- ages exist. The tremendous changes that have been occurring in the capital and credit requirements of agriculture have resulted in a widening of the gap between the demand for farm credit and the supply of funds with which the rural banks may meet it. The rate of increase in farm debt during the 60's has been substantially greater than the rate of increase in deposits in rural banks. The loan-to-deposit ratios of these banks have risen steadily to a level where for many the future expansion of loans is impossible if they maintain adequate liquidity positions. Although banking has retained its number one position as a supplier of farm credit, its share of the total outstanding debt has decreased from 28% in 1959 to 26% today. I therefore applaud the Federal Reserve Board's decision to study the 11 agricultural credit problems in capital deficient areas and possibilities for their amelioration through improvements in the market- ability of bank agricultural paper", as announced in the March issue of the Federal Reserve Bulletin. Continued. GERALD FORD LIBRARY THE AMERICAN BANKERS ASSOCIATION CONTINUING OUR LETTER OF May 27, 1970 SHEET No. 2 In February the A.B.A.'s Agricultural and Rural Affairs Committee, realizing the urgency of this problem, established a subcommittee to deal with the question of sources of funds for rural banks. I feel strongly that the entire banking industry needs to focus attention on this matter. I wish therefore to encourage the Federal Reserve Board to give high priority to its study. In addition I want to offer the A.B.A.'s assist- ance, especially through its Agricultural and Rural Affairs Committee which is chairmaned by Mr. Edward M. Norman, President of The First National Bank, Clarksville, Tennessee. The Board's Study Committee should feel free to call on Mr. Norman as well as the members of our special subcommittee which includes: Thomas J. Prosser, President, The National Manufacturers Bank, Neenah, Wisconsin, CHAIRMAN; Grant W. Perry, Senior Vice President, First National Bank of Oregon, Portland, Oregon, and; George R. Reid, Senior Vice President, The First National Bank and Trust Company, Stillwater, Oklahoma. An adequate supply of loanable funds will be one of the critical problems that must be met if rural banks are to remain viable institutions during the 70's. I sincerely believe that the Federal Reserve Board, by initiating this study, has taken an important step to help banks to serve the agricultural credit needs of the Nation. nats Sincerely, Rogers NSR:1cc Nat S. Rogers President CC: Hugh Galusha, Jr. Edward M. Norman Thomas Prosser E FORD i LIBRARY GERALD JUN 9 1970 Mr. Not S. Rogers, President, The American Bankers Association, 90 Park Avenue, New York, New York. 10016 Dear Nat: Chairman Burns has asked BMB to let you know he appreciates the sentiment conveyed in your letter of May 27 concerning the Federal Reserve announced study of agricultural credit problems. We are glad as well to have the offer of assistance from the ABA's Agricultural and Rural Affairs Committee. I am passing along your letter to Hugh Galusha, the chairman of the recently established Federal Reserve System committee to pursue the announced study. I have no doubt that one of our consittee representatives will be in touch with Mr. Norman in due course. Yours sincerely, (Signed) Robert C. Holland Robert C. Holland, Secretary of the Board. ee: Mr. Galusha be: Governor Mitchell Mrs. Mallardi (2) FORD & LIBRARY GERALD BH-17 THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N. Y. 10016 NAT S. ROGERS PRESIDENT FIRST CITY NATIONAL BANK HOUSTON, TEXAS 77001 May 27, 1970 The Honorable Arthur F. Burns Chairman Board of Governors Federal Reserve System Washington, D. C. 20551 Dear Mr. Chairman: The American Bankers Association, through the activities of its Agricultural and Rural Affairs Committee, has encouraged rural banks to stay in the forefront as full financial service centers in their communities. A considerable part of this effort has been directed toward a better understanding of the various sources of funds available to banks in rural areas where often seasonal or even longer-term short- ages exist. The tremendous changes that have been occurring in the capital and credit requirements of agriculture have resulted in a widening of the gap between the demand for farm credit and the supply of funds with which the rural banks may meet it. The rate of increase in farm debt during the 60's has been substantially greater than the rate of increase in deposits in rural banks. The loan-to-deposit ratios of these banks have risen steadily to a level where for many the future expansion of loans is impossible if they maintain adequate liquidity positions. Although banking has retained its number one position as a supplier of farm credit, its share of the total outstanding debt has decreased from 28% in 1959 to 26% today. I therefore applaud the Federal Reserve Board's decision to study the = agricultural credit problems in capital deficient areas and possibilities for their amelioration through improvements in the market- ability of bank agricultural paper", as announced in the March issue of the Federal Reserve Bulletin. FORD & LIBRARY GERALD Continued THE AMERICAN BANKERS ASSOCIATION CONTINUING OUR LETTER OF May 27, 1970 SHEET No. 2 In February the A.B.A.'s Agricultural and Rural Affairs Committee, realizing the urgency of this problem, established a subcommittee to deal with the question of sources of funds for rural banks. I feel strongly that the entire banking industry needs to focus attention on this matter. I wish therefore to encourage the Federal Reserve Board to give high priority to its study. In addition I want to offer the A.B.A.'s assist- ance, especially through its Agricultural and Rural Affairs Committee which is chairmaned by Mr. Edward M. Norman, President of The First National Bank, Clarksville, Tennessee. The Board's Study Committee should feel free to call on Mr. Norman as well as the members of our special subcommittee which includes: Thomas J. Prosser, President, The National Manufacturers Bank, Neenah, Wisconsin, CHAIRMAN; Grant W. Perry, Senior Vice President, First National Bank of Oregon, Portland, Oregon, and; George R. Reid, Senior Vice President, The First National Bank and Trust Company, Stillwater, Oklahoma. An adequate supply of loanable funds will be one of the critical problems that must be met if rural banks are to remain viable institutions during the 70's. I sincerely believe that the Federal Reserve Board, by initiating this study, has taken an important step to help banks to serve the agricultural credit needs of the Nation. nats Sincerely, Rogers NSR: 1cc Nat S. Rogers President CC: Hugh Galusha, Jr. Edward M. Norman Thomas Prosser GERALD FORD LIBRARY Mrs. Mallara June 10, 1970 Dear Willis: I appreciate your invitation to attend the ABA convention in October, but already my schedule for that period is such that I will have to regretfully decline. However, Bill Sherrill tells me that he and his wife are planning to attend, and I know they will ably represent the Federal Reserve at the meeting. My best wishes for a successful convention, Sincerely yours, (Signed) Arthur F. Burns Arthur F. Burns Mr. Willis W. Alexander Executive Vice President The American Bankers Association 90 Park Avenue New York, New York 10016 RCH:ck FORD & LIBRARY GERALD BH DA M 5 THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N.Y. 10016 WILLIS W. EXECUTIVE VICE PRESIDENT June 1, 1970 The Honorable Arthur F. Burns, Chairman Board of Governors of the Federal Reserve System Constitution Avenue Washington, D. C. 20551 Dear Dr. Burns: The 96th Annual Convention of The American Bankers Association will be held in Miami Beach, Florida, on October 10-14, 1970. On behalf of the officers of the Association, it is my pleasure to extend you a cordial invitation to attend our convention. An application for housing accommodations is enclosed for your use. If you plan to be at our convention and need hotel accom- modations, please fill out the form promptly and mail it to: A.B.A. Convention Housing Bureau Mrs. Edith J. Shapiro, Housing Supervisor 1700 Washington Avenue Miami Beach, Florida 33139 Please also let me know if you plan to attend in order that later we may arrange to send you a complimentary advance convention registration. Yours sincerely, Willi W. Alexandr Enclosures LISRARY GERALD FORD ?) FR 373 HJ6.1 BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM Date June 6, 1970. To Mr. Holland From Catherine Mallardi Is it necessary for the Chairman to attend this? He'd like to limit his attendance as much as possible. Attachment to for [P.S I assume a reply should be drafted. 1g] FORD i LIBRARY GERALD THE AMERICAN BANKERS ASSOCIATION 96th ANNUAL CONVENTION MIAMI BEACH, FLORIDA OCTOBER 10-14, 1970 APPLICATION FOR HOUSING ACCOMMODATIONS The Honorable Arthur F. Burns, Chairman THIS APPLICATION FORM IS FOR YOUR Board of Governors of the Federal Reserve OWN EXCLUSIVE USE. System Constitution Ave. IF OTHERS FROM YOUR BANK OR Washington, D. C. 20551 OFFICE DESIRE TO APPLY FOR HOTEL ACCOMMODATIONS, THEY SHOULD USE THE REGULAR APPLICATION FORM. PLEASE FILL OUT THIS APPLICATION FORM COMPLETELY AND MAIL IT TO: A.B.A. Convention Housing Bureau Mrs. Edith J. Shapiro, Housing Supervisor 1700 Washington Avenue Miami Beach, Florida 33139 HOTEL ACCOMMODATIONS DESIRED. (IT is NECESSARY THAT THREE CHOICES OF HOTELS BE LISTED BELOW.) CHOICE HOTEL TYPE OF ROOM DESIRED (CHECK ONE) 1ST ONE SINGLE BED 1 PERSON 2ND ONE DOUBLE BED 2 PERSONS 3RD TWIN BEDS 2 PERSONS TWIN STUDIO 2 PERSONS PARLOR & ONE BEDROOM 2 PERSONS INDICATE APPROXIMATE RATE $ IF ACCOMMODATIONS ARE NOT AVAILABLE AT ANY OF THE ABOVE HOTELS, THE HOUSING BUREAU WILL ATTEMPT TO MAKE YOUR RESERVATION AT ANOTHER SUITABLE PLACE. THERE WILL BE AN INTERVAL OF SEVERAL WEEKS BEFORE YOU WILL RECEIVE A ROOM CONFIRMATION. ROOM NUMBERS CANNOT BE ASSIGNED BY HOTELS UNTIL GUESTS REGISTER ON arrival. CONVENTION ADVANCE REGISTRATION INFORMATION WILL BE SENT AUTOMATICALLY TO THOSE WHOSE HOUSING RESER- VATIONS HAVE CLEARED THROUGH THE A.B.A. CONVENTION HOUSING BUREAU. A.M. ROOM WILL BE OCCUPIED BY MYSELF ONLY ARRIVING HOUR P.M. (DATE) MYSELF AND WIFE LEAVING (DATE) FORD i LIBRARY GERALD SIGNATURE THE AMERICAN BANKERS ASSOCIATION 96TH ANNUAL CONVENTION MIAMI BEACH, FLORIDA OCTOBER 10-14, 1970 PLEASE ROUTE TO OFFICER RESPONSIBLE FOR APPLYING FOR A.B.A. CONVENTION HOTEL ACCOMMODATIONS. A.B.A. CONVENTION ANNOUNCEMENT The 96th Annual Convention of The American Bankers Association will be held in Miami Beach, Florida, October 10-14, 1970. This is your bank's official 1970 convention notification. HOUSING ACCOMMODATIONS Enclosed are: A list of convention hotels/motels, a map showing their locations, a schedule of room rates, and an official Application for Housing Accommodations form. As in previous years, this letter was mailed on a staggered basis, based on post office mail schedules, so that banks in all parts of the country should have received their letters simultaneously. Rooms will be assigned on a priority basis. The basis for this priority will be the date on the post office cancellation stamp on the envelope used by the bank to mail the official Application for Housing Accommodations form. Since the date of the mailing of the application is the controlling factor, this plan gives everyone an "even start.' The only exceptions to this priority rule will be in the assignment of rooms to certain officers of the Association, speakers, government officials, and the limitation which will be placed on the number of rooms any bank may have in certain hotels as explained on page 2. Because of the anticipated large attendance at the convention a "convention headquarters hotel" is not designated. HOUSING PROCEDURE To facilitate the processing of your application, it is essential that you fill the form out completely, giving five choices of hotels, rates, time of arrival and departure, and the names of room occupants. Rooms will not be assigned unless the names of the occupants are stated on the form. FORD & LIBRARY GERALD ROOM RATE SCHEDULE We suggest you do not attempt to secure accommodations by asking Miami Beach banks to obtain space for you. Such procedure will not improve your chances. 96th Annual Convention In fact, it might operate in just the opposite manner because of the delay The American Bankers Association involved in getting the application to the Housing Bureau. The Bureau will October 10-14, 1970, Miami Beach, Florida honor only an official Application for Housing Accommodations form. Hence, a Miami Beach bank acting as intermediary would only occasion delay. Other banks would be getting priority on rooms requested directly from the Housing BEDROOMS PARLOR SUITES Bureau during the period of your correspondence with the Miami Beach bank. HOTEL/MOTEL It is suggested, therefore, that you send your application directly to the SINGLE DOUBLE OR TWIN 1 Bedroom 2 Bedrooms Housing Bureau rather than ask a local bank to try to get housing accommodations Algiers $16 $18 $40 $60 for you. Americana 18-28 18-28 61--78 91-106 Regardless of any prior request you may have made for housing accommodations to any hotel/motel, to the A.B.A. Convention Housing Bureau, or to The American Balmoral 18-26 18-26 56--66 82--92 Bankers Association, assignments will be made only from the official Application Barcelona 14 16 & 18 36 -- for Housing Accommodations forms which have been properly completed. Beau Rivage 14-20 14--20 44--52 70 Please send the Application for Housing Accommodations to: Cadillac 14 16 35 -- Carillon 16 & 18 20 & 22 45 & 50 65 & 75 A.B.A. Convention Housing Bureau Mrs. Edith J. Shapiro, Housing Supervisor Casablanca 15 18 -- -- 1700 Washington Avenue Crown 15 16--18 -- -- Miami Beach, Florida 33139 Deauville 16-22 16--22 38--56 66--84 Should you later find it necessary to cancel or make any change in your Doral Beach 20-30 20-30 69--75 93-105 reservation, please notify Mrs. Shapiro immediately. Telephone: (312) 532-5215. Eden Roc 16-26 16--26 35* & 70 94 Applications will be processed as rapidly as possible and every effort will be Fontainebleau 16-30 16-30 50 & 75 85 & 125 made to assign applicants to the hotel/motel they prefer. However, several weeks will elapse before assignments are made and confirmations mailed. Harbour House S. 14 & 18 14 & 18 -- -- Holiday (22nd St.) 15 17 37 64 Holiday (87th St.) 18 18 -- -- HOUSING LIMITATIONS IN CERTAIN HOTELS Ivanhoe 14 21 & 26 60 90 You will agree that our limited allotment of rooms in certain of the more popular Kenilworth 15-21 15-21 60 -- hotels should be spread among as many of our members as possible. This we will Lucerne 14 & 15 16-20 38 54 try to do. But it is necessary that even those banks which reply early be restricted. Therefore, if sizable numbers of persons are to be registered at Montmartre 16--22 16--22 44 66 the convention from one bank, these persons should not all request housing in the same hotel. It is suggested that someone in the bank send a priority list Plaza 20-30 20-30 65 100 to Mrs. Shapiro at the time the Application for Housing Accommodations is mailed. Sans Souci 15 17 -- -- This will enable the Housing Bureau to process reservations more efficiently and to assign individuals to various hotels more nearly in accordance with the desires Saxony 15 16--18 -- -- of those individuals. SeaView 18-28 18-28 63 & 68 -- Seville 16 & 18 17-21 45 -- For guidance, the restriction in the more popular hotels will be that any bank (and obviously only as long as rooms are available) will be limited for sleep- Twelve Caesars 12 12 28 42 ing accommodations to a total of five rooms (counting a parlor and bedroom as two rooms). The five rooms might be in one or divided among several of the *A few Jr. (studio) suites available at $35. following hotels: Americana, Doral Beach, Eden Roc, Fontainebleau, and Plaza. BAY HARBOR Harbour House S. HOTEL/MOTEL ADDRESSES ADVANCE CONVENTION REGISTRATION ISLANDS Kenilworth Ivanhoe 0.5 miles BAL HARBOUR Early in the summer those whose housing reservations have cleared through the Broad Causeway Beau Rivage Sea View Balmoral ADDRESS ON A.B.A. Convention Housing Bureau will automatically receive forms and 96th. St. Americana HOTEL/MOTEL COLLINS AVENUE instructions for registering in advance for the convention. All advance 8614 ST Twelve Caesars 2555 registrations must be received prior to September 18 in order for the names Algiers 9701 to be printed in the registration list. Americana Balmoral 9801 INDIAN Barcelona 4343 If it is not necessary for you to process your housing reservation through the SURFSIDE CREEK Beau Rivage 9955 A.B.A. Convention Housing Bureau, as would be the case for representatives VILLAGE Cadillac 3925 from banks in the local area, and you desire to have your name appear in the 88th. St. Carillon 6801 printed registration list, it is suggested that you obtain an advance Holiday (87th) Casablanca 6345 registration form from: Crown 4041 Collins Ave. Deauville 6701 Advance Registration Doral Beach 4833 The American Bankers Association Eden Roc 4525 90 Park Avenue Fontainebleau 4441 New York, N. Y. 10016 Harbour House S. 10275 Holiday (22nd St.) 2201 All persons (including wives) attending the convention must be registered. 71st St. Holiday (87th St.) 8701 71st ST. Ivanhoe 10175 CONVENTION MEETINGS AND ACTIVITIES Kenilworth 10205 Carillon 5.2 miles Lucerne 4101 Meetings will be held in a number of hotels. So that you may plan your arrival Deauville GERCE Montmartre 4775 and departure time, as well as arrange for transportation accommodations, the ISLAND Plaza 5445 following schedule has been arranged: 63rd. St. Sans Souci 3101 Casablanca Saxony 3201 Saturday 10 a.m. Exhibits and Registration Area open. Road Drive SeaView 9909 Oct. 10 Seville 2901 Twelve Caesars 9449 MIAMI Sunday Morning & Committee Meetings. Oct. 11 afternoon BEACH Pine Tree Creek Plaza 4:30-6 p.m. Reception for convention registrants. Alton Monday 9:30 a.m. Marketing/Savings Division--General Meeting. Oct. 12 State Bank Division--General Meeting. 47th. Ave, Trust Division--General Meeting. St. unipul Doral Beach Montmartre Collins 2 p.m. National Bank Division--General Meeting. Eden Roc 5:30 p.m. Executive Council--business meeting for Arthur Godfrey Rd. Fontainebleau 1969-70 Council members. Barcelona Lucerne Crown Tuesday 9:45 a.m. First General Convention Session. Cadillac Oct. 13 2 p.m. Workshops. 2.1 miles 8:30 p.m. Entertainment for registrants. Saxony Sans Souci Wednesday 9:45 a.m. Second General Convention Session. Seville Oct. 14 Algiers 12:30 p.m. (New) Executive Council--meeting and Holiday (22nd) luncheon for 1970-71 Council members. CONVENTION HALL Lincoln Rd. TRANSPORTATION The American Bankers Association does not arrange for special trains or planes to and from the convention. This is sometimes done by certain state groups. Therefore, any inquiry you have regarding special trains or planes from your area should be made directly to the managing officer of your state bankers association. POST-CONVENTION TRIPS AND TOURS You may receive material from travel agencies, airlines, steamship companies, and others advertising "pre-convention" or "post-convention" trips or tours. The American Bankers Association is not in any way endorsing or sponsoring any convention trips or tours this year. The decision to take such a trip is one for individual determination. We hope you will attend the convention in Miami Beach in October, and we urge you to request your housing and make your transportation reservations promptly. Melmul Miller Melvin C. Miller Convention Director 2 June 1970 (202) 298-9090 WASHINGTON OFFICE THE AMERICAN BANKERS ASSOCIATION 815 CONNECTICUT AVENUE, N. W., WASHINGTON, D. C. 20006 FEDERAL ADMINISTRATIVE ADVISER July 15, 1970 WILLIAM T. HEFFELFINGER Mrs. Catherine Mallardi Secretary to Dr. Arthur J. Burns Board of Governors of the Federal Reserve System Washington, D. C. 20250 Dear Mrs. Mallardi: I am enclosing for the information of Chairman Burns a list showing the members of the Government Borrowing Com- mittee of the A.B.A. Most of these members will be present for the July 28 meeting, although there will be a few absentees. I am sure the Committee will appreciate the oppor- tunity of discussing the Treasury's financing problems with Chairman Burns as they did for so many years with Chairman Martin. Previous practice has been for the Chairman or Vice Chairman to come over to our offices, Room 1002, at 815 Connecticut Avenue, and meet with the Committee in our Board Room. Sincerely yours, W. T. Heffelfinger WTH: TB Enclosure FORD & LIBRARY GERALD COMMITTEES OF THE A.B.A. GOVERNMENT BORROWING COMMITTEE FREDERICK G. LARKIN. JR. GEORGE S. CRAFT Chairman of board, Security Chairman of board, Trust Com- Pacific National Bank, P. O. Box pany of Georgia, P.O. Box 4418, 2097, Terminal Annex, Los An- Atlanta, Georgia 30302 geles, California 90054, Chairman GEORGE S. ECCLES WILLIAM T. HEFFELFINGER President, First Security Bank of Federal administrative adviser Utah, N.A., P. O. Box 390, Salt and senior deputy manager, Lake City, Utah 84110 A.B.A., Washington Office, Sec- retary DAVID ROCKEFELLER Chairman and chief executive of- ficer, The Chase Manhattan Bank, TERM EXPIRING 1970 N.A., P. O. Box 65, Church Street WILLIAM G. FOULKE Station, New York, N. Y. 10008 Chairman and chief executive ROBERT V. ROOSA officer, Provident National Bank, Partner, Brown Brothers Harri- P. O. Box 7648, Philadelphia, man & Co., 59 Wall Street, New Pennsylvania 19101 York, N. Y. 10005 JAMES P. HICKOK KENNETH V. ZWIENER Chairman of board, First Na- Chairman of board, Harris Trust tional Bank, P. O. Box 267, St. and Savings Bank, P. O. Box 755, Louis, Missouri 63166 Chicago, Illinois 60690 FREDERICK G. LARKIN, JR. TERM EXPIRING 1972 Chairman of board, Security Pacific National Bank, P. O. Box Robert M. Surdam, President 2097, Terminal Annex, Los An- Chairman, National Bank of De: and Chief Executive geles, California 90054 troit, P. O. Box 116, Detroit, Michigan 48232 Officer JOHN M. MEYER, JR. THOS. O. COOPER Chairman and chief executive officer, Morgan Guaranty Trust President, South Des Moines Na- Company, P. O. Box 495, Church tional Bank, P. O. Box 2630, Des Street Station, New York, N. Y. Moines, Iowa 50315 10015 GAYLORD A. FREEMAN, JR. WILLIAM S. RENCHARD Chairman of board, The First Chairman, Chemical Bank, New National Bank, P. O. Box A, Chi- York, N. Y. 10015 cago, Illinois 60670 RUSS M. JOHNSON EMMETT G. SOLOMON Chairman of board and chief Chairman and chief executive executive officer, Deposit Guar- officer and chairman of executive anty National Bank, P. O. Box committee. Crocker-Citizens Na- 1200, Jackson, Mississippi 39205 tional Bank, P. O. Box 3066, Rin- con Annex, San Francisco, Cali- WILLIAM H. MOORE fornia 94120 Chairman oj board, Bankers Trust Company, P. O. Box 318, Church Street Station, New York, TERM EXPIRING 1971 N. Y. 10015 MILLS H. ANDERSON WALTER B. WRISTON President, Bank of Carthage, President. First National City P.O. Drawer 637, Carthage, Mis- Bank, 399 Park Avenue, New souri 64836 York, N. Y. 10022 68 FORD is LIBRARY GERALD - 2 - ADVISORY MEMBERS EX OFFICIO Charles J. Gable, Jr. Clifford C. Sommer, President Executive Vice President Security Bank and Trust Company First Pennsylvania Bank P. 0. Box 467 P. 0. Box 7558 Owatonna, Minnesota 55060 Philadelphia, Pennsylvania 19101 (Vice President, A.B.A.) John J. Larkin J. Howard Laeri, Vice Chairman Senior Vice President First National City Bank First National City Bank P. O. Box 161, Grand Central Station 55 Wall Street New York, New York 10017 New York, New York 10015 (Past President, A.B.A.) Donald C. Miller Douglas R. Smith Senior Vice President Chairman of Board and President Continental Illinois National Bank National Savings and Trust Company and Trust Company Washington, D. C. 20005 Lock Box H (Chairman, A.B.A. Savings Bonds Chicago, Illinois 60690 Committee) Paul I. Wren Nat S. Rogers, President Chairman of Board and Chief First City National Bank, Executive Officer P. 0. Box 2557 Old Colony Trust Company Houston, Texas 77001 P. O. Box 2016 (President, A. B. A.) Boston, Massachusetts 02106 Willis W. Alexander, Executive Vice President, A. B. A. Dr. Thomas A. Atkinson, Di rector, Economic Research Dept., American Bankers Association 90 Park Avenue, New York, N. Y. 10016 FORD & LIBRARY GERALD AGENDA GOVERNMENT BORROWING COMMITTEE THE AMERICAN BANKERS ASSOCIATION July 28, 1970 Tuesday, July 28, 1970 9:15 a.m. Committee meets in Board Room of The American Bankers Association 815 Connecticut Avenue, N. W. (Suite 1002) 10:00 a.m. Committee to review slides in Room 2334 of the Treasury Department 1/ 11:00 a.m. Committee to meet with Under Secretary for Monetary Affairs, Paul Volcker, in Room 4426 of the Treasury Department 1/ 12:30 p.m. Reception - - Cabinet Room 1:00 p.m. Lunch - Pan American Room Mayflower Hotel 2:30 p.m. Committee to reconvene in Board Room of The American Bankers Association 3:45 p.m. Chairman Burns Federal Reserve Board 5:15 p.m. Committee to report its recom- mendations to Secretary Kennedy and the Treasury Financing Group in Room 4426 of the Treasury 1/ Treasury will use the regular projection room on the second floor on Southwest corner of building (corner facing the Mall and the White House). Conference with Under Secretary for Monetary Affairs and report to the Secretary of the Treasury will be held in the fourth floor Conference Room on West side of building near the center elevators opposite the White House. FORD & LIBRARY GERALD Bit THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N.Y. 1001 NAT S. ROGER PRESIDEN FIRST CITY NATIONAL BAN HOUSTON, TEXAS 770C July 28, 1970 The Honorable Arthur F. Burns Chairman Board of Governors of the Federal Reserve System Washington, D. C. 20551 Dear Chairman Burns: The purpose of this letter is to express the concern of The American Bankers Association with regard to the discriminatory interest rate differentials, as between Federally insured banks and non-federally insured mutual savings banks in Massachusetts. In brief, the problem now confronting all Federally regulated commercial banks in that state is one of competitive unfairness resulting from the interest rate ceilings of 4.5% on regular savings deposits and 5% on 90 day notice accounts currently imposed by the Federal Reserve under Regulation Q (12 C.F.R. 217.7) and parallel Regulation 329.6 (12 C.F.R. 329.6) of the F.D.I.C. while Massachusetts mutual savings banks not under Federal regulation are permitted under state regulation to offer 5.25% and 5.5% on the same types of deposits. A review of the most recent legislation on the extension of interest rate regulatory authority is in order to place the current Massachusetts situation in proper perspective. Both the Senate and House bills contained language providing for the extension of the Federal interest rate control authority to non-Federally insured financial institutions wherever state officials lacked comparable authority and non-insured savings deposits in the state exceed 20% of the total savings deposits. During the hearings before the Banking and Currency Committees of both Houses of Congress, your agency as well as the F.D.I.C. endorsed this provision. Such support was based, for the most part, on the principle of competitive equality and fairness and on the belief that to permit certain institutions to escape Federal interest rate control would tend to undermine the reasons for such control and also would be a disruptive force against regulated institutions unable to compete. Notwithstanding the objections of the Massachusetts savings banks and the Massachusetts Banking Commissioner, this provision was adopted in both Houses. GERALD FORD LIBRARY THE AMERICAN BANKERS ASSOCIATION CONTINUING OUR LETTER OF July 28, 1970 SHEET No. : Under this authority, the F.D.I.C. can only prevent rate increases on the deposits of these non-Federally insured insti- tutions above 5.5% until July 31, 1970. After that date, the Federal agencies would have complete authority unless a state gave its Banking Commissioner full authority to establish maximum rates in which case it would be exempt from Federal authority. Massachusetts has now passed legislation authorizing the State Banking Commissioner to control interest rates of these non-Federally insured institutions. The Commissioner has announced her intention of establishing rates of 5.25% on regular savings accounts and 5.5% on notice accounts -- thus creating a differential of 3/4 of 1% more than the rate allowed on savings deposits of commercial banks and 1/2 of 1% more than the rate allowed on commercial bank 90 day notice accounts. This compares to a 1/2 of 1% spread on savings deposits and a 1/4 of 1% spread on 90 day notice accounts. generally prevailing in all other states. The American Bankers Association has long advocated the elimination or narrowing of this rate differential in favor of thrift institutions. Such differential should not exceed 1/2 of 1% and preferably, 1/4 of 1%. Accordingly, in view of the announced intention of the Massachusetts Bank Commissioner, the American Bankers Association on behalf of our member banks in Massachusetts, both state and national, respectfully requests that the Board review their current interest rate regulations in light of the circumstances now prevailing in Massachusetts and that all Federally insured banks in that state be authorized to pay 4.75% on regular savings accounts and 5.25% on 90 day notice accounts. Such action would thus permit Federally insured commercial banks to compete for savings deposits on the same comparable basis as commercial banks in other states. We firmly believe that such action is imperative for the continued viability of the commercial banking system in Massachusetts and is justified under both the Federal Reserve Act (12 U.S.C. 371(b)) and the Federal Deposit Insurance Act (12 U.S.C. 1828(g)) which both provide in part: " The Board of may prescribe different rate limitations for different classes of deposits, for deposits of different amounts or with different maturities or subject to different conditions regarding withdrawal or repayment, according to the nature or location of ... banks or their depositors, or according to such other reasonable bases as the Board of may deem desirable in the public interest. " FORD & LIBRARY GERALD (underscoring added) Sincerely, not A Rogers OF JO-BOARD CHAIRMAN OF THE BOARD OF GOVERNORS SYSTEM FEDERAL RESERVE SYSTEM THE WASHINGTON, D.C. 20551 August 27, 1970. Mr. Nat S. Rogers, President American Bankers Association 815 Connecticut Avenue Washington, D. C. 20006 Dear Mr. Rogers: I am responding to your letter of May 25, 1970, requesting the Board to issue a statement of policy in support of the billion- dollar commitment of the banking industry to assist in developing minority business enterprise. We believe the proposed program of the banking industry is worthwhile and are pleased to see that the Association's undertaking has the needed support of the commercial banks. The problems of the nation's cities and its disadvantaged minorities are areas in which commercial banks can make a most important contribution to progress. In the Board's judgment, the more loans to disadvantaged minorities the better, provided they are sound. Implicit in this policy is the understanding that banks will furnish guidance and assistance to members of minority groups in connection with their borrowings. However, in examining banks, a loan to a disadvantaged person or firm must be evaluated just as any other loan - that is, on the basis of the ability of the borrower to make timely repayment and his record of performance. We hope that your program will be successful. Sincerely yours, as 23m Arthur F. Burns FORD & LIBRARY GERALD BH THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N.Y. 10016 NAT S. ROGERS PRESIDENT FIRST CITY NATIONAL BANK HOUSTON, TEXAS 77001 May 25, 1970 Please reply to: 815 Connecticut Avenue, N. W. Washington, D. C. 20006 The Honorable Arthur F. Burns Chairman Board of Governors of the Federal Reserve System Washington, D. C. Dear Doctor Burns: Earlier this month, The American Bankers Association, through its Urban Affairs Committee, announced the banking industry's intention to achieve a goal of $1 billion in minority business lending. Much of this lending activity will take the form of "soft" loans, for which traditional credit requirements have been relaxed so as to encourage maximum prudent utilization of credit by minority entrepreneurs. A number of these loans will be written in conjunction with guaranty programs of the Small Business Administration. We are aware that a policy regarding examin- ation of such guaranteed loans was enunciated by the Comptroller of the Currency in a January 3, 1969, memorandum to all examining personnel and the regional administrators of national banks, and by the Federal Deposit Insurance Corporation in a January 24, 1969, memorandum from the Chief, Division of Examination, FDIC, to all FDIC examiners and assistant examiners. To the best of our knowledge, however, the federal examining agencies have not yet established a policy concerning "soft" minority business loans which do not possess the guaranty of an agency of the Federal Government. We believe such loans are consistent with the Administration's commitment to encourage the develop- ment of minority enterprise. In each case where credit is advanced, the lending bank feels there exists reasonable ability to repay the loan on the basis of terms prescribed. Yet, because FORD i LIBRARY GERALD THE AMERICAN BANKERS ASSOCIATION CONTINUING OUR LETTER OF May 25, 1970 SHEET No. 2 of the greater risks involved, such loans cannot be judged by the same standards as the normal business loans banks are accustomed to making. Several bankers have already expressed concern as to how federal bank examiners will view the marginal credit aspects of these loans. To allay such concerns, and to assure maximum bank participation in fulfilling the expectations of minority enterprise, it would be very helpful if a favorable policy S tatement regarding the attitude of your organization toward these loans could be issued by your office to the examining staffs and, in turn, passed on to the banks. If you agree that such a statement of policy in support of the commitment to assist in developing minority business enterprise is desirable, we shall appreciate receiving a copy which can then be disseminated to participating banks. You may be interested in the enclosed statement concerning the industry's commitment to minority business enterprise. Sincerely yours, nat Nat S. Rogers cc: Thomas W. McMahon, Jr. Chairman, Urban Affairs Committee Enclosure 1 FORDO & GERALD LIBRARY STATEMENT BY THOMAS W. McMAHON, JR. EXECUTIVE VICE PRESIDENT, THE CHASE MANHATTAN BANK, N. A. CHAIRMAN, URBAN AFFAIRS COMMITTEE OF THE AMERICAN BANKERS ASSOCIATION It has been about five years now since the attention of the nation has been sharply focused on the problems of its cities and its disadvantaged minorities. During that period, many solutions have been tried by both the public and private sectors of our society. Some programs have been successful, others were not. It has been a trial-and-error process on a variety of fronts -- such as providing a minimum level of family income, working for physical neighborhood rehabilitation and stimulating economic development. Many commercial banks have been at the forefront of these attempts to improve the quality of life for the less advantaged. Banks are at the heart of the nation's economic system and their success is inextricably tied to the well-being of the communities they serve. Indeed, a survey released earlier this month by the A. B.A. Urban Affairs Committee revealed that 81% of the 188 banks responding are firmly committed to policies aimed at improving the cities, reducing poverty, providing equal opportunity for all and fostering an improved quality of life. And most of these banks have undertaken specific programs in these areas. But it is in the areas most germane to banking -- the lending of money -- that commercial banks can make a most important contribution. During recent years, the banks that have made loans to minority enterprise have learned much about how to maximize the borrower's -- the individual minority entrepreneur's -- chances for success. FORD is LIBRARY 9ERALD -2- We believe that we have come far and are confident enough in our knowledge and our ability to transmit it throughout the industry. Therefore, we -- representing the American commercial banking industry -- have committed ourselves to a goal of $1 billion in loans to minority businesses over the next five years. The loans we are talking about often involve abnormal risks because the applicants lack the entrepreneurial "know-how" or capital normally required to qualify for bank credit. The loans will be made -- a billion dollars worth -- at normal interest rates. The term "minority enterprise" is frequently thought of as denoting only very small businesses located in and serving disadvantaged areas of the nation's cities. We have to broaden that definition to include profitable, minority-owned manufacturing, retail and service businesses capable of competing in the economic mainstream. Granting loans such as these involves far more than merely approving the credit of a customer who walks through the door of the bank and fills out an application. Because the applicants are men and women who often lack the necessary experience and training to go into business "on a standard-risk basis, granting these loans requires a significant investment in manpower by the lending banks to provide managerial counseling and assistance. This includes special guidance in such areas as operations, accounting and marketing. The American Bankers Association is, therefore, adopting a "key cities" approach, identifying a number of major cities -- about fifty -- where the need is greatest. Under the "key cities" program, in each of the cities identified for a sharply focused and localized effort, bankers collectively will be encouraged to organize a bankers committee on urban affairs. It is hoped that because of differences from GERALD FORD VIBRARY -3- city to city, this approach will have maximum impact. Local bankers urban affairs committees already exist in New York, Philadelphia, and Chicago. Another problem area that we've learned about from our experience is that, because of the difficulties involved in starting a business today, which are often compounded for blacks and other minority group members, there is lacking a sizable backlog of loan prospects. Add to that other factors such as inadequate capital and preparation, and it is understandable why there is not greater call for this type of loan. However, we as an industry plan to aggressively seek out potential minority-group entrepreneurs. The American Bankers Association also feels that it is important at this time to reaffirm the basic principles of its urban involvement. The A. B.A. has therefore adopted an Urban Affairs Policy Statement which reaffirms the commercial banking industry's commitment to an aggressive policy of equal opportunity employment, to local economic development, to better housing, to support of community organizations and to cooperation with federal, state and local efforts to overcome the highly complex and interrelated problems of our cities. Copies of this policy statement are available for you. I think this is a significant document, for it spells out in no uncertain terms the commitment of commercial banks -- an important segment of the economic fiber of our nation -- to programs to solve some of 1 the important problems facing the nation and its cities, and the people who live and work in them. In the last five years, we have learned much. We have seen which programs work and which do not. We have identified the vital conditions and ingredients for FORD & LIBRARY GERALD -4- effective programs. And we have learned that no matter how lofty the intentions of a national headquarters, effective programs can be carried out only with the dedication, the organizationæd the know-how at the local level. To encourage local action in a concrete way, we have planned a series of Urban Development Seminars in each of the key cities. Teams of visiting specialists will meet with senior management to convey the rationale and the type of organization necessary for an effective urban affairs program. They will also meet with middle management on a nuts-and-bolts basis, to present the proper program strategy and organization, case studies, information on supportive government programs, relation- ships with senior management, with the community and with outside organizations, and distribute materials to help them get the job done. Since banks do not ordinarily segregate their loans by race or by neighborhood, dollar figures for the industry's present commitment are, at best, an approximation. The 90 banks that answered this limited survey's questions relating to lending activities had made more than 21, 000 loans totaling almost $100 million to minority businesses during the year ending June 30, 1969 and almost 37, 000 loans of $1.3 billion for low- income housing during the same period. Because so few banks were surveyed and loan records have not been maintained on a racial basis, actual outstanding loans for the industry cannot now be ascertained. The experience of bankers who have been engaged in this type of lending activity thus far has demonstrated that while there are indeed great risks involved, there is also an opportunity for entrepreneurship and profit that frequently makes the risks worthwhile. Moreover, in terms of potential economic impact on the nation's racial and urban problems, they are risks that we as bankers want to take. FORD & LIBRARY GERALD -5- I have mentioned some of the problems that we will face in meeting our billion dollar goal. Undoubtedly, we will encounter many more before the goal is met. However, we recognize the importance of the task that we have undertaken and we are confident that we have the strength of commitment, as well as the technical knowledge, to succeed. And I am confident that we will. And now, ladies and gentlemen, if you have any questions about this program, I shall be happy to try to answer them. FORD & LIBRARY GERALD L6BD THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N.Y. 10016 NAT S. ROGERS PRESIDENT FIRST CITY NATIONAL BANK HOUSTON, TEXAS 77001 September 4, 1970 The Honorable Arthur F. Burns Chairman Board of Governors of the Federal Reserve System Washington, D.C. Dear Mr. Chairman: I had hoped to be able to present this letter in person. However, since the effective date of the Home Loan Bank Board Regulation is September 14 and there is a need for prompt consideration, I am having it delivered today. I hope to have the opportunity to visit with you in person when I am in Washington next week. Sincerely, nats. Nat S. Rogers Rogers called for appointment FORD on Indry 9/11/70 i LIBRARY GERALD yes - mo THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N.Y. 10016 NAT S. ROGERS PRESIDENT FIRST CITY NATIONAL BANK HOUSTON, TEXAS 77001 September 4, 1970 Dr. Arthur F. Burns Chairman Board of Governors of the Federal Reserve System Washington, D. C. 20551 Re: Federal Home Loan Bank Board Regulation 12 C.F.R. 545, 555 Dear Mr. Chairman: The Federal Home Loan Bank Board has recently adopted amendments to its regulations, effective September 14, which will permit Federal savings and loan associations to honor non-negotiable authorizations by account holders in Federal savings and loan associations for payment to third parties, including direct transfers to the savings account of third parties, periodically or otherwise. The American Bankers Association along with others protested to the Federal Home Loan Bank Board regarding the issuance of these regulations. Nevertheless, the Board put the regulations into effect a year after their first publication in the Federal Register. The American Bankers Association urges the Federal Reserve Board to use its influence to bring about the withdrawal of these regulations for the following reasons: (1) The regulations of the Federal Home Loan Bank Board exceed the authority granted in the Housing and Urban Development Act of 1968 to permit "withdrawal of savings accounts upon non-transferable order or authorization. " The legislative history makes it clear that this provision was not intended to permit Federal savings and loan associations to accept demand deposits or to establish a new type of payment mechanism which has many of the attributes of checking accounts. (2) Under these regulations the distinction between demand and savings deposits would be blurred and the effectiveness of the Federal Reserve Board in controlling monetary conditions could be impaired. FORD & LIBRARY GERALD Dr. Arthur F. Burns Page 2 September 4, 1970 Payment of interest on deposit balances available for transfer to third parties will be attractive to private individuals and corporations where this type of deposit is made available. This ability to attract additional deposits will encourage many Federal savings and loan associations to offer this type of payment mechanism. These advantages could reduce the need for demand deposits and could permit Federal savings and loan associations to acquire funds which otherwise would go into demand deposits of commercial banks. Under these circumstances, there would be decreases in commercial bank deposits which are subject to monetary control while at the same time the accounts of savings and loan associations would in effect operate as part of the money supply, but would do so outside the direct control of the Federal Reserve. Thus, the effectiveness of the Federal Reserve in exercising its monetary policy would be frustrated. (3) The new regulations permitting payment of interest by Federal savings and loan associations on deposits that are essentially demand in character would involve a major change in the payments mechanism and the relationship of financial institutions. We believe that questions of this importance should not be acted upon until the Presidential Commission on Financial Structure and Regulation has had an opportunity to consider the proposal along with other problems involving our financial system. If, however, the Federal Home Loan Bank Board persists in retaining the regulations with respect to transfer payments, we urge the Federal Reserve Board and the Federal Deposit Insurance Corporation to recognize the inequities which may result and, therefore, to extend comparable authority to commercial banks. As indicated above, the ability of Federal savings and loan associations to offer payment transfer services from interest-bearing accounts will afford a powerful attraction to the development of new accounts from both individuals and corporations. These associations will be able to develop many arrange- ments for handling consumer and corporate payments through interest-bearing savings accounts with required reserves (lower than bank reserves) invested in earning assets. Electronic equipment and computer technology may add further impetus to direct transfer arrangements. In order for commercial banks to maintain a fair degree of competitive equality, it is essential that they be permitted to offer comparable services. Moreover, if the commercial banking system and the Federal Reserve are to continue to play the central role in the payments system, it is most important not to encourage the diversion of large volumes of payments and transfers into new channels. If new transfer methods are to be authorized, they should also be available through the existing payments mechanism. FORD i LIBRARY GERALD Dr. Arthur F. Burns Page 3 September 4, 1970 If the regulation is permitted to take effect, The American Bankers Association urges the Federal Reserve Board and the Federal Deposit Insurance Corporation to permit commercial banks to make comparable payments and transfers from interest-bearing savings and time accounts to third parties and to accept corporate deposits in savings accounts. Sincerely yours, not s. Rogers Nat S. Rogers FORD is LIBRARY 938870 FEDERAL HOME LOAN BANK BOARD No. 70-94 Date: August 4, 1970 TITLE 12 - BANKS AND BANKING Chapter V - Federal Home Loan Bank Board Subchapter C - Federal Savings and Loan System Part 545 : Operations Part 555 - Board Rulings AMENDMENTS RELATING TO SERVICES RENDERED BY FEDERAL SAVINGS AND LOAN ASSOCIATIONS RESOLVED that, notice and public procedure having been duly afforded (34 F.R. 13481) and all relevant material presented or available having been considered by it, the Federal Home Loan Bank Board, upon the basis of such consideration, determines to amend Parts 545 and 555 of the Rules and Regulations for the Federal Savings and Loan System (12 CFR Parts 545 and 555) for the following purposes: 1. To implement the last sentence *subsection (b) (1) of section 5 of the Home Owners' Loan Act of 1933 as added by Section 1716 of the Housing and Urban Development Act of 1968, Public Law 90-448, 90th Congress, approved August 1, 1968, by providing for the withdrawal or trans- fer of savings accounts in Federal savings and loan asso- ciations upon nontransferable order or authorization. 2. In order to increase the effectiveness of Federal savings and loan associations in encouraging thrift by making their facilities available to the public generally, to authorize such associations to provide for the sale of checks, includ- ing travelers checks and money orders, thereby extending the scope of such activity previously permissible under the ruling referred to in item 3 hereof. 3. To revoke an existing ruling in paragraph (d) of $ 555.8 of said Part 555 which would be supplanted by the regula- tion amendments herein. FORD & LIBRARY GERALD Accordingly, the Federal Home Loan Bank Board hereby amends said Parts 545 and 555 as follows, effective September 14, 1970: FEDERAL HOME LOAN BANK BOARD No. 70-94 Page Two 1. Part 545 is amended by adding a new § 545.4-1, immediately after § 545.4 to read as follows: § 545.4-1 Payments to third parties by withdrawals or transfer of savings accounts; checks and money orders. (a) Withdrawals and transfers. Savings accounts in a Federal association shall not be subject to check or to withdrawal or transfer on negotiable or transferable order or authorization to the association. However, withdrawal requests" may be in the form of nontransferable orders or authorizations to the association for the payment of amounts in savings accounts to third parties periodically or otherwise. Any such order or authorization which may be honored as a withdrawal request for payment to a third party may, if so authorized by the third party, also be honored as a transfer to a savings account of such third party. The association may charge a fee for its services in making any payment or transfer pursuant to this section. Any form for such orders or authorizations shall contain language in bold- face type of reasonable size to the effect that the order or authorization is not negotiable or transferable. (b) Sale of checks and money orders. As an incident to its principal activities and for the convenience of its members and others, a Federal association may provide for the sale of checks, including travelers checks, and money orders on which the drawee is a Federal Home Loan Bank, commercial bank, or other organization engaged in the business of handling such instruments. 2. Part 555 is amended by revoking paragraph (d) of § 555.8. (Sec. 5, 48 Stat. 132, as amended; 12 U.S.C. 1464. Reorg. Plan No. 3 of 1947, 12 F.R. 4981, 3 CFR, 1943-48 Comp., P. 1071) FORD GERALD LIBRARY By the Federal Board DEC 11 1969 TO: Board of Governors SUBJECT: Proposed authorized payment plan and deposit transfer FROM: Division of Research and Statistics Power for Savings and Loan (Mr. Struble) Associations. The Home Loan Bank Board has published a proposed change in regulation which would give savings and loan associations authority to honor shareholder requests in the form of nonnegotiable or non- transferrable orders or authorizations to pay amounts in savings accounts to third parties; transfer affected by checks or other nego- tiable instruments would continue to be prohibited. The nontransferrable orders or authorizations could designate payment of a single obligation. In addition, orders or authorizations instructing the association to pay a member's periodic obligations--such as a utility bill--could be honored even if the amounts to be paid were not specified. A second important part of this FHLBB proposal is that these orders or authorizations could be honored by direct transfer to a savings account of a third party, if the third party agreed to this arrangement. The comments to follow offer an analysis of the economic implications of this proposal including its implications for the pay- ments mechanism and for monetary policy. Before proceeding to this discussion, it might be worth summarizing two of its major points. Those aspects of the proposal reviewed in the first paragraph above will, if adopted, significantly increase the substitutability of deposits at savings and loan associations with demand deposits at FORD & LIBRARY GERALD -2- commercial banks. The aspect of the proposal reviewed in the second paragraph, if adopted, would make possible the development of a payment system wholly independent of the present payment system based on demand deposit accounts at commercial banks and the mechanism for clearing checks written on these accounts. How Will These Plans Develop? Before any evaluation of the economic implications of the FHLBB proposal can be made, it is necessary to formulate some conception of how these plans will work and how extensive they might become. The immediate discussion to follow offers some tentative answers to these questions. Activities prohibited. It appears that only those payment transactions in which a check--a negotiable instrument--is used to make payment on an obligation to a third party would be prohibited. While such a restriction may have been important in past years, it should be emphasized that it will not necessarily be so in the future. After all, most projections of the evolution of the payments mechanism contend that the check is scheduled for eventual obsolescence. Thus, the long-run development of these payment plans at savings and loan associations would not appear to be particularly confined by this restriction. Near-term development. It seems unlikely that these payment plans would assume major significance in the near term following their authorization. Part of the rationale for this conclusion is that, to date, preauthorized payment plans based on demand deposits at commercial FORD i LIBRARY GERALD -3- banks have not proven to be very popular, as most people seem reluctant to have payments automatically deducted from their account. Moreover, a large number of S&L's will in all probability be quite reluctant to offer these plans to the public because of the prospective increase in costs to be incurred in servicing accounts. Support for this latter assumption is provided by several letters the FHLBB received from S&L's in which they objected to this proposal on the grounds that the industry could not bear the added costs associated with operating these plans. While these factors will serve to hold back an immediate burgeoning of these plans, it seems unlikely that they will retard their development entirely. The opportunity to earn interest on a "transactions" balance should overcome the reluctance which many people have to entering into this type of arrangement. And, some S&L managers will probably conclude that the costs of operating these plans will be more than covered by the revenue to be derived from the additional deposit funds generated. Thus, it seems likely that during the initial period of introduction these payment plans will take hold and begin growing but at a comparatively moderate pace. Although the extent of the development which will occur over these early years cannot be foreseen with any degree of accuracy, one thing seems certain to occur: commercial banks will observe the potential competitive challenge of these plans and will urge strongly that they be given the opportunity to offer similar plans based on their savings deposit accounts. FORD & LIBRARY GERALD -4- Longer-run developments. Despite an initial reluctance, it seems likely that plans of this kind probably would be destined to assume increased importance with the passage of time. Developing forces such as the unfolding computer technology, for example, will both permit and encourage a payment mechanism based upon some form of money transfer other than a check. The mounting volume of paper work generated by the present check clearing system can also be cited, for it has led to considerable bank interest in alternative types of payments arrangement. Finally, expansion of charge account purchases- of which increasing credit balances associated with bank credit cards and other revolving credit arrangements are the most dramatic--should be mentioned, since the growing practice of per- mitting repayment of account balances on an instalment basis would appear to be well suited to the operation of these plans. The shareholders, for example, could simply authorize the S&L to pay the minimum balance due on his revolving credit arrangement with a department store or commercial bank. If to these basic forces one adds the opportunity to obtain an interest return on what are essentially "transaction" balances, then it appears that these plans-- whether based on deposit accounts at S&L's or on savings accounts at commercial banks--are sure to spread. A fairly detailed sketch of the potential activities of these S&L plans can be presented which meets the test of reasonableness in the sense that it does not appear to be in conflict with existing laws and appears entirely feasible on operational grounds. GERALD R. FORD LIBRARY -5- After operating these payment plans on a limited basis for a period of time needed to gain experience, some savings and loans might well opt to expand its activities by advertising something like the following plan. 1. Arrange with your employer to have at least part of your paycheck automatically credited to your savings and loan account. 2. In return for placing these funds with us, we will pay in- terest daily on the balance you maintain with us. (It seems quite unlikely that the interest rate offered under these arrangements will match that being offered on other types of savings accounts, because the expenses of operating this payments mechanism will have to be met. Alternatively, S&L's may offer uniform rates on all their savings accounts but charge specific fees for the services they provide in making payments.) 3. We will, after receiving your authorization, pay amounts from your account to meet your periodic bills. 4. In addition, you may sit down once or twice a month and fill in pertinent information with regard to your other bills on one of our authorization slips. After we receive this authorization in the mail, we will carry out your instructions. (Presumably, the obligations handled through these payment plans will encompass the vast majority of all payments which have to be made by an ordinary household during the month, since most retail purchases, including even grocery store purchases, might well be' transacted through charge accounts by this time.) FORD i LIBRARY CERALD -6- 5. If you need any cash during this period simply come to our office. Or, if that is not convenient, simply mail in an authorization slip and we will send you a money order which you can conveniently turn into cash. In fact, if you wish, you may authorize us to send you periodically a money order of a given amount. (This discussion assumes that another change in regulation, proposed by the FHLBB at the same time as the one under discussion in this memorandum, is adopted. This proposal would permit a Federal savings and loan association to "provide for the sale of checks, including traveler's checks, and money orders on which the drawee is a Federal Home Loan Bank, commercial bank, or other organization engaged in the business of handling such instruments.") This is but one sketch of the type of arrangement which S&L's could conceivably offer to a customer. Many others would be possible, for if present proposed regulations are adopted, the S&L's will have great flexibility in designing these plans. And, given this flexibility, it is logical to assume that the associations will develop arrangements capable of handling most types of consumer payments. Consequently, these plans could become extremely popular. Savings and Loan Payments Transfer System When these payment plans are first established, S&L's will carry out the payment instructions of their shareholders by debiting the shareholder's account for the amount of the payment in question. The S&L will then present a check, written on its deposit account at a commercial bank, to the designated third party specifying in the process that the check is to serve as payment for the bills of the FORD & LIBRARY GERALD -7- shareholder. Thus, initially the completion of payments under these payment plans will be closely tied to the existing check clearing system. But as these plans evolve, it seems quite possible (and indeed quite likely) that they will begin to break away from the use of checks and could eventually become essentially divorced from the check clearing system. This potential course of development would appear to be made possible by the last sentence in the FHLBB's proposal-- that is, that transfers can be made to the account of a third party in payment to that party, if the third party agrees. For example, it would appear likely that S&L's would attempt to encourage business firms in their immediate area to whom large payments for household customers are made to hold deposit balances with them. There is nothing in existing laws to prohibit firms of this type from holding balances with S&L's, and it seems quite possible that S&L's would induce these firms to do so as a convenience to all concerned. Indeed, the S&L will offer to pay an interest rate as an inducement to the establishment of such accounts, and might even agree to transfer an account balance after it reaches a certain level. The transfer could be made to commercial bank accounts or perhaps to the account of a security dealer--who may also have an account with the S&L--to pay for securities acquired in the name of the deposit customer. The precise nature of the transfer would, of course, be established by agreement. No matter to whom the transfer is made, it seems a reasonably safe presumption that, as time passes, such transactions would tend increasingly to take the form of a direct transfer of credit balances rather than a trans fer of funds through the mechanism of a check. GERALD LIBRARY -8- Coinciding with these developments on a local level, it also is conceivable that S&L's in different regions of a State or in different sections of the country would begin entering into arrangements which would facilitate the transfer of funds among associations. Separate service corporations could be established to aid with the process of clearing intra-State transfers, while interstate transfers arrangements might be developed in several ways. For example, facilities could be developed at the Federal Home Loan Banks for inter-District settlements, just as banks now clear through the Federal Reserve Banks. The sketch presented above is, of course, but one possible course of development. But despite its tentative nature, it does serve to illustrate that the potential would exist for the development of a payment system independent of one operated through transactions based on deposit accounts at commercial banks. What is envisioned, is an arrangement not too different from the "post giro" systems which operate independently of the check clearing system in many European countries. Economic Implications Improved efficiency of check clearing. It seems reasonably clear that authorized-preauthorized payment plans whether operated by S&L's or by commercial banks will improve the efficiency of the is LIBRARY GERALD existing check clearing system. To illustrate this point, consider a hypothetical situation in which initially 100 households are making monthly payments to the same 10 business firms and that each house- hold pays each bill with a check on its demand deposit account. Under this arrangement a total of 1,000 checks would have to pass through -9- the check clearing system. Then assume that these households decide to utilize the payment plan service of a savings and loan association. Each household would then send one check to the S&L to cover its total monthly liabilities. The S&L, in turn, would send one check drawn on its bank account to each of the 10 firms to pay the bills of its 100 household customers. The total number of checks required to clear though the check clearing system under this arrangement would be 110. Thus, a significant reduction in items to be cleared is achieved. Admittedly, the degree of conformance between the firms to be paid and the customers of a single S&L, as described here, is probably larger than would normally occur in actual practice. Yet, this example does indicate the potential economies to be gained by consolidating the bills of a large number of customers and discharging these obligations with a single payment. It should be stressed that similar economies would be obtained from bank operated payment plans, whether these plans are based on savings deposits or demand deposits. Other possibilities for cutting back the volume of checks could also arise from the operation of payment plans. For example, household wage earners might direct their employers to deposit their paychecks directly in S&L accounts. This would eliminate the need for householders to write checks on their bank account in order to increase their S&L deposit account. And if S&L's are successful in inducing firms to establish accounts with them, then the payment of bills to these firms could be completed without any check being written at all. GERALD FORD LIBRARY -10- An even further possible source of reduction in check clearing activity might arise from this arrangement, for it is just possible that once firms are able to earn interest on a transaction balance they may be less inclined toward the practice of attempting to economize cash balances by shifting from deposits into open market instruments. The decrease in the volume of paperwork to be cleared by the financial system as a whole will not be as extensive as might appear from the focusing only on the drop in the volume of checks to be cleared. The S&L's and banks offering the services of these plans will, after all, experience a sharp step-up in paperwork in performing these services. But on net balance some cost reduction should be achieved. Deposit instability. It appears likely that individual savings accounts used as a basis for these payment plans will fluctuate more than they do presently. However, whether this will result in a substantial increase in the volatility of aggregate savings and loan accounts will depend upon the success these institutions have in synchronizing the volume of their deposit inflows with the volume of their deposit outflows. Payments could be staggered by arranging to pay utilities on one day, insurance companies on the next, etc., or by arranging to pay on any one day the bills of only a proportionately small number of deposit customers to these various firms. This would reduce the tendency for payment obligations to bunch up on a given day. In addition, payments could be scheduled to coincide with deposit in- flows, and the volume of inflows could be evened out by obtaining deposit customers who receive their paycheck on different days. Thus, GERALD LIBRARY -11- while it is clear that the activity and fluctuation associated with individual accounts are certain to rise, the extent of increase in the volatility of deposit accounts in the aggregate remains a matter for conjecture. In addition, assuming that the funds to establish these S&L payment plan accounts are attracted from commercial bank demand deposits, then during this transition period, deposit instability at commercial banks could also increase. It also seems likely that sub- stituting payments based on S&L accounts for payments based on demand accounts at banks will alter (perhaps significantly) traditional seasonal (and perhaps cyclical) patterns of deposit fluctuations at commercial banks. The liquidity problems generated by this augmenting of deposit instability are obvious. Savings and loan associations will have to develop procedures for minimizing the instability of their total deposit balances and to expand existing arrangements for obtain- ing cash to meet unexpected deposit outflows. The liquidity problem facing commercial banks will be no less acute, particularly during the transition period, for presumably banks will experience a steady erosion in their demand deposit accounts--assuming that traditional restrictions on demand accounts are retained--and will have to develop procedures for meeting these deposit declines. Implications for economic stability and monetary policy Preauthorized-authorized payment plans based on savings deposits will reduce demand for money (defined as demand deposits GERALD FORD LIBRARY -12- adjusted plus currency) relative to a given volume of transactions or a given level of income, unless major changes are made in existing regulations which would permit banks to pay interest on their demand balances. However, during the early stages of development this de- cline will be moderate for two reasons: a) because these plans will not be offered in all areas of the country and even where they are offered they will presumably restrict the types of payments which can be made so that households will continue to need money to pay for a large proportion of their transactions; and b) because S&L's will need to increase their demand deposit balances at commercial banks in order to complete the enlarged volume of payments they will have to make. However, S&L's presumably will be able to handle a given volume of transactions with lower average demand deposit balances than those maintained by households so that, on net, demand for money will decline, but only moderately. Such moderate changes in demand for money, and related changes in velocity, would not appear to present any significant problem in the administration of monetary policy. However, as time passes and these payment plans become more pervasive, it seems clear that demand for money, as presently defined, may begin to erode significantly, because these payment plans do appear to have the potential to become important substitutes for demand deposits. As discussed above, the importance of the check as a means of payment seems destined to diminish considerably with the onset of new technology. And in an age in which charge account purchasing is FORD i LIBRARY GERALD -13- spreading steadily, the possibility of having to wait 30 days before gaining control over funds held in a savings account will not be con- sidered much of a handicap, particularly if, as seems likely, the probability of such a development is thought to be quite small. Traditional relationships between money, bank credit, and developments in other financial aggregates may become distorted as a result of this substitution process as will the relationship of any of these aggregates to GNP and other economic variables. This will tend to increase the difficulty of evaluating the significance of monetary aggregates, particularly in the transition period. Once the transition period is concluded, new relatively stable--at least no less stable than now--relationships between monetary aggregates, other assets, credit market conditions and economic activity presumably will emerge. But the transition period may be fairly lengthy and conditions during that period may be quite turbulent, as more and more household cash balances are shifted to savings account forms in more and more associations or shifted to savings accounts at banks, if banks were given the same authority as S&L's. Distinctions between money and other liquid assets, for example, will become decidedly blurred during this transition period. This, of course, is not an entirely new phenomenon, particularly when one considers the long standing post-World War II trend in which time deposits at commercial banks and mutual savings banks and savings shares at S&L's have been substituted for demand deposits at banks. But this trend of developments has been reasonably steady and orderly GERALD FORD LIBRARY -14- so that, even though the implications of this trend have not been entirely understood, they have had their impact on a fairly gradual basis. During the early stages of the evolution of preauthorized payment plans it is to be expected that this substitution process will remain gradual. But as time goes on, it is possible that these plans could begin to catch on with a rush, resulting in sharp structural changes over short periods of time. Competitive Equity If savings and loan associations are given the authority to operate preauthorized-authorized payment plans several issues will be raised regarding the impact of this change on competitive arrangements between associations and commercial banks and between savings deposit accounts and demand deposit accounts. Moreover, depending upon how these issues are resolved, several problems with regard to determining the type of regulations to apply to different types of accounts at different institutions and the means for coordinating the implementation of these regulations will be encountered. If S&L's receive authority to operate these plans then it seems certain that commercial banks will request authority to operate similar plans based on their savings deposit accounts. But if payment plans based on savings accounts prove popular--and at least eventually this seems likely to occur--then the issue of why interest can be paid on what are essentially transactions balances held in savings accounts but cannot be paid on demand deposit may well be raised. In addition, FORD i LIBRARY GERALD -15- there will be the question of why reserve requirements against transactions balances held in demand deposits should be higher than reserve require- ments against similar balances held in time deposits. And more will be involved here than simply the question of reserve ratios: the types of assets to qualify as reserves will have to be considered. Why, commercial banks are sure to ask, must we hold reserves in the form of deposit balances at Federal Reserve Banks which provide a zero interest return while S&L's are permitted to hold their reserves in the form of interest-bearing Treasury securities. Finally, assume for the moment that a proposal is offered to resolve these various issues by requiring S&L's to hold reserves in the form of zero interest earning deposits at the Federal Home Loan Banks, that reserve ratios on all deposits are equalized, and that the in- terest prohibition on demand deposits is eliminated. At least one additional issue would remain which is, what relative rates of growth in reserves would be allowed by the Federal agencies generating these reserves. At a minimum it seems likely that very close coordination of reserve policies will be required. FORD is LIBRARY GERALD -16- CONCLUDING COMMENT Preauthorized-authorized payment plans will quite probably play an important role in the completion of payments transactions in the future. The evolution of computer and electronics technology will permit and indeed should promote such payments arrangements. Expansion of purchases financed through credit card plans and other revolving credit arrangements should also help to promote the applicability and thereby the growth of payment plans. The introduction of these plans will reduce the volume of checks required to complete a given volume of transactions so that some improvement in efficiency of the payment system is to be expected even over the fairly short-run future. Over the longer-run these plans could easily lead to the development of a credit transfer payment system operated by commercial banks and S&L's. If S&L's are given permission to make credit transfers the result could eventually be the development of a payment transfer system which operates essentially independently of the commercial bank system. During the period in which these plans would be introduced and established it seems certain that financial institutions would encounter increased difficulty with deposit instability. The monetary authorities would be confronted with problems no less difficult, as traditional relationships among financial variables and between financial variables and other economic variables will be distorted. And the in- creased difficulty encountered in interpreting financial developments BERALD FORD LIBRARY -17- will be accompanied by equally acute problems with regard to influencing these conditions, since the reins by which the monetary authority has traditionally exercised control will be loosened. But perhaps the most difficult problems generated by the proposal to give S&L's the authority to operate preauthorized-authorized payment plans are those involving questions of the competitive position of various financial institutions and various types of deposits. Prudence would appear to demand that, in consideration of these many potential problems and issues, considerable caution should be exercised in their adoption. Preferably this would seem to point to the need for prior study and resolution of all the technical and regulatory issues to be created by the introduction and operation of these plans. If this ideal approach is not acceptable, however, it would seem wise to at least move gingerly. One course of action meeting this criteria might be initially to prohibit S&L's from making credit transfers among their accounts. Another may be to limit the debits (and also credits if these are permitted) to certain types of trans- actions, such as mortgage or rent payments, or payments on utility bills. FORD & LIBRARY GERALD September 10, 1970 To: Board of Governors Subject: Permitting business From: Legal Division (R. F. Sanders) corporations to have savings deposits. This memorandum, prepared at Governor Maisel's request, is designed to furnish some background material that might be helpful to Board members in connection with the anticipated discussion of this topic by the Federal Advisory Council at its meeting with the Board tomorrow. (See ABA's letter of September 4, 1970, page 3.) It is assumed that Board members will not wish to discuss the merits of the arguments, outlined below, for and against the Board amending Regula- tion Q to permit business corporations to have savings deposits. However, it is hoped that the material will give the Board some idea of the issues involved. In my opinion, amending Regulation Q to permit business corporations to have savings deposits would be a valid exercise of the Board's authority to define the terms used in section 19 of the Federal Reserve Act. (In 1963, Comptroller of the Currency Saxon published an interpretation indicating that national banks could, despite Regulation Q, offer savings deposits to business corporations; however, Comptroller Camp has withdrawn that interpretation.) Arguments for the change are: (1) Savings and loan associations accept comparable accounts from business corporations; all federally insured financial institutions should be subject to the same rules governing savings and time deposits, except for the differential in rate designed to avoid undesirable shifts of funds from one class of institution to another. This is implicit in the interest-rate-control legislation enacted by the Congress in 1966. (2) Unlike the situation when the Board drew the distinction between persons eligible for savings deposits and those who are not, the Board now permits a higher rate of interest on time deposits than on savings deposits. Although the original concept underlying savings deposits was to encourage thrift, that is an anachronism in view of the present rate structure. (3) Prohibiting business corporations (and municipal corporations) from having savings deposits is a distinction based on the nature of the depositor that cannot be justified on the basis of economic considerations. In some respects, the distinction appears to be arbitrary; for example, a school district may have a savings deposit but a board of education may not. Maintaining the distinction has taken an inordinate amount of the time of the Board and its staff over the years. The reasons for maintaining the distinction do not justify the effort involved. FORDO i LIBRARY GERALD Board of Governors -2- Arguments against the change are: (1) The number of corporations that maintain savings deposits in S&Ls is nominal compared with the number that could be expected to open such accounts in member banks. This is true today and would remain so after the FHLBB regulations regarding preauthorization of payments from savings deposits in S&Ls become effective. The desirability of one-stop banking will still favor deposits in commercial banks. (2) Permitting business corporations to have savings deposits would result in a marked decline in the amount of demand deposits. Although it might not be worthwhile for an individual to make daily transfers from his savings account to his checking account to meet his needs for funds on a daily basis, large business corporations probably would find that procedure worthwhile. If so, corporations would tend to retain the bulk of their funds in savings deposits. (It would seem advantageous to member banks to have corporations shift their funds from demand to savings deposits, because that would reduce sub- stantially their reserve requirements, unless the Board only permits corporate savings deposits for the purposes of Regulation Q and not for the purposes of Regulation D.) This possibility is sufficiently likely to raise a legal question whether permitting corporate savings deposits is consistent with the statutory prohibition in section 19 against payment of interest on demand deposits. (3) It is unnecessary to permit member banks to have corporate savings accounts to eliminate much of the present administrative burden involved. Excluding only corporations operated for profit from having savings deposits and permitting all municipal authorities to have such deposits would substantially reduce the amount of time required to administer this aspect of Regulation Q. FORD & LIBRARY GERALD CHAIRMAN BURNS For Information Only BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM Office Correspondence Date September 9, 1970. To Board of Governors and Subject: New regulations of FHLBB providing fund transfer authority for From Robert C. Holland payment of accountholders' bills. As mentioned in the memorandum dated September 8, 1970 from the Office of the Secretary, the Federal Advisory Council has added to the agenda for its upcoming September 11 meeting with the Board, the subject of the new regulations of the Federal Home Loan Bank Board providing fund transfer authority for payment of account- holders' bills. For reference in connection with that discussion, there is attached a letter on this matter received today from the American Bankers Association. Staff memoranda on the subject are in preparation for distribution to the Board for consideration at a reasonably early date. Attachment FORD & 07VR70 LIBRARY THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N.Y. 10016 NAT S. ROGERS PRESIDENT FIRST CITY NATIONAL BANK HOUSTON, TEXAS 77001 September 4, 1970 The Honorable Arthur F. Burns Chairman Board of Governors of the Federal Reserve System Washington, D.C. Dear Mr. Chairman: I had hoped to be able to present this letter in person. However, since the effective date of the Home Loan Bank Board Regulation is September 14 and there is a need for prompt consideration, I am having it delivered today. I hope to have the opportunity to visit with you in person when I am in Washington next week. Sincerely, nats Nat S. Rogers GERALD FORD LIBRARY THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N.Y. 10016 NAT S. ROGERS PRESIDENT FIRST CITY NATIONAL BANK HOUSTON, TEXAS 77001 September 4, 1970 Dr. Arthur F. Burns Chairman Board of Governors of the Federal Reserve System Washington, D. C. 20551 Re: Federal Home Loan Bank Board Regulation 12 C.F.R. 545, 555 Dear Mr. Chairman: The Federal Home Loan Bank Board has recently adopted amendments to its regulations, effective September 14, which will permit Federal savings and loan associations to honor non-negotiable authorizations by account holders in Federal savings and loan associations for payment to third parties, including direct transfers to the savings account of third parties, periodically or otherwise. The American Bankers Association along with others protested to the Federal Home Loan Bank Board regarding the issuance of these regulations. Nevertheless, the Board put the regulations into effect a year after their first publication in the Federal Register. The American Bankers Association urges the Federal Reserve Board to use its influence to bring about the withdrawal of these regulations for the following reasons: (1) The regulations of the Federal Home Loan Bank Board exceed the authority granted in the Housing and Urban Development Act of 1968 to permit "withdrawal of savings accounts upon non-transferable order or authorization. " The legislative history makes it clear that this provision was not intended to permit Federal savings and loan associations to accept demand deposits or to establish a new type of payment mechanism which has many of the attributes of checking accounts. (2) Under these regulations the distinction between demand and savings deposits would be blurred and the effectiveness of the Federal GERALD FORD LIBRARY Reserve Board in controlling monetary conditions could be impaired. runu GERALD LIBRARY Dr. Arthur F. Burns Page 2 September 4, 1970 Payment of interest on deposit balances available for transfer to third parties will be attractive to private individuals and corporations where this type of deposit is made available. This ability to attract additional deposits will encourage many Federal savings and loan associations to offer this type of payment mechanism. These advantages could reduce the need for demand deposits and could permit Federal savings and loan associations to acquire funds which otherwise would go into demand deposits of commercial banks. Under these circumstances, there would be decreases in commercial bank deposits which are subject to monetary control while at the same time the accounts of savings and loan associations would in effect operate as part of the money supply, but would do so outside the direct control of the Federal Reserve. Thus, the effectiveness of the Federal Reserve in exercising its monetary policy would be frustrated. (3) The new regulations permitting payment of interest by Federal savings and loan associations on deposits that are essentially demand in character would involve a major change in the payments mechanism and the relationship of financial institutions. We believe that questions of this importance should not be acted upon until the Presidential Commission on Financial Structure and Regulation has had an opportunity to consider the proposal along with other problems involving our financial system. If, however, the Federal Home Loan Bank Board persists in retaining the regulations with respect to transfer payments, we urge the Federal Reserve Board and the Federal Deposit Insurance Corporation to recognize the inequities which may.result and, therefore, to extend comparable authority to commercial banks. As indicated above, the ability of Federal savings and loan, associations to offer payment transfer services from interest-bearing accounts will afford a powerful attraction to the development of new accounts from both individuals and corporations. These associations will be able to develop many arrange- ments for handling consumer and corporate payments through interest-bearing savings accounts with required reserves (lower than bank reserves) invested in earning assets. Electronic equipment and computer technology may add further impetus to direct transfer arrangements. In order for commercial banks to maintain a fair degree of competitive equality, it is essential that they be permitted to offer comparable services. Moreover, if the commercial banking system and the Federal Reserve are to continue to play the central role in the payments system, it is most important not to encourage the diversion of large volumes of payments and transfers into new channels. If new transfer methods are to be authorized, they should also be available through the existing payments mechanism. Dr. Arthur F. Burns Page 3 September 4, 1970 If the regulation is permitted to take effect, The American Bankers Association urges the Federal Reserve Board and the Federal Deposit Insurance Corporation to permit commercial banks to make comparable payments and transfers from interest-bearing savings and time accounts to third parties and to accept corporate deposits in savings accounts. Sincerely yours, not s. Rogers Nat S. Rogers FORD i LIBRARY GERALD September 9, 1970. Mr. Nat S. Regers, President, The American Bankers Association, 90 Park Avenue, New York, New York. 10016 Dear Mat: 1 want to be quick to acknowledge, in Chairman Burns' absence, your letter of Suptember 4, 1970 concerning recent regulatory emendments adopted by the Federal Home Loan Bank Board. The Board of Governors has been following developments in this area closely, and I can assure you the Board will give prompt and careful consideration to the views set forth in your letter. Yours sincerely, Robert C. Holland, Secretary of the Board. be: Mr. Sanders Mr. Kenyon Mr. Axilrod Mr. Eckert Mr. Leonard Mrs. Mallardi (2) FORD is LIBRARY GERALD L6BH THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N.Y. 100 NAT S. ROGEI PRESIDE FIRST CITY NATIONAL BA HOUSTON, TEXAS 77C September 4, 1970 The Honorable Arthur F. Burns Chairman Board of Governors of the Federal Reserve System Washington, D.C. Dear Mr. Chairman: I had hoped to be able to present this letter in person. However, since the effective date of the Home Loan Bank Board Regulation is September 14 and there is a need for prompt consideration, I am having it delivered today. I hope to have the opportunity to visit with you in person when I am in Washington next week. Sincerely, nats. Nat S. Rogers Rogers called for appointment FORD on Inday 9/11/70 is LIBRARY GERALD yes - no THE AMERICAN BANKERS ASSOCIATION 90 PARK AVENUE, NEW YORK, N.Y. 10016 NAT S. ROGERS PRESIDENT FIRST CITY NATIONAL BANK HOUSTON, TEXAS 77001 September 4, 1970 Dr. Arthur F. Burns Chairman Board of Governors of the Federal Reserve System Washington, D. C. 20551 Re: Federal Home Loan Bank Board Regulation 12 C.F.R. 545, 555 Dear Mr. Chairman: The Federal Home Loan Bank Board has recently adopted amendments to its regulations, effective September 14, which will permit Federal savings and loan associations to honor non-negotiable authorizations by account holders in Federal savings and loan associations for payment to third parties, including direct transfers to the savings account of third parties, periodically or otherwise. The American Bankers Association along with others protested to the Federal Home Loan Bank Board regarding the issuance of these regulations. Nevertheless, the Board put the regulations into effect a year after their first publication in the Federal Register. The American Bankers Association urges the Federal Reserve Board to use its influence to bring about the withdrawal of these regulations for the following reasons: (1) The regulations of the Federal Home Loan Bank Board exceed the authority granted in the Housing and Urban Development Act of 1968 to permit "withdrawal of savings accounts upon non-transferable order or authorization. 11 The legislative history makes it clear that this provision was not intended to permit Federal savings and loan associations to accept demand deposits or to establish a new type of payment mechanism which has many of the attributes of checking accounts. (2) Under these regulations the distinction between demand and savings deposits would be blurred and the effectiveness of the Federal Reserve Board in controlling monetary conditions could be impaired. FORD & LIBRARY GERALD Dr. Arthur F. Burns Page 2 & LIBRARY 9ERALD September 4, 1970 Payment of interest on deposit balances available for transfer to third parties will be attractive to private individuals and corporations where this type of deposit is made available. This ability to attract additional deposits will encourage many Federal savings and loan associations to offer this type of payment mechanism. These advantages could reduce the need for demand deposits and could permit Federal savings and loan associations to acquire funds which otherwise would go into demand deposits of commercial banks. Under these circumstances, there would be decreases in commercial bank deposits which are subject to monetary control while at the same time the accounts of savings and loan associations would in effect operate as part of the money supply, but would do so outside the direct control of the Federal Reserve. Thus, the effectiveness of the Federal Reserve in exercising its monetary policy would be frustrated. (3) The new regulations permitting payment of interest by Federal savings and loan associations on deposits that are essentially demand in character would involve a major change in the payments mechanism and the relationship of financial institutions. We believe that questions of this importance should not be acted upon until the Presidential Commission on Financial Structure and Regulation has had an opportunity to consider the proposal along with other problems involving our financial system. If, however, the Federal Home Loan Bank Board persists in retaining the regulations with respect to transfer payments, we urge the Federal Reserve Board and the Federal Deposit Insurance Corporation to recognize the inequities which may result and, therefore, to extend comparable authority to commercial banks. As indicated above, the ability of Federal savings and loan associations to offer payment transfer services from interest-bearing accounts will afford a powerful attraction to the development of new accounts from both individuals and corporations. These associations will be able to develop many arrange- ments for handling consumer and corporate payments through interest-bearing savings accounts with required reserves (lower than bank reserves) invested in earning assets. Electronic equipment and computer technology may add further impetus to direct transfer arrangements. In order for commercial banks to maintain a fair degree of competitive equality, it is essential that they be permitted to offer comparable services. Moreover, if the commercial banking system and the Federal Reserve are to continue to play the central role in the payments system, it is most important not to encourage the diversion of large volumes of payments and transfers into new channels. If new transfer methods are to be authorized, they should also be available through the existing payments mechanism. Dr. Arthur F. Burns Page 3 September 4, 1970 If the regulation is permitted to take effect, The American Bankers Association urges the Federal Reserve Board and the Federal Deposit Insurance Corporation to permit commercial banks to make comparable payments and transfers from interest-bearing savings and time accounts to third parties and to accept corporate deposits in savings accounts. Sincerely yours, Nat s. Rogers Nat S. Rogers FORD i LIBRARY GERALD BYT WILL NCP TUND 1 FR 373 new mallards BOARD OF GOVERNORS OF THE FEDERAL reserve SYSTEM Date 9/9/70 To Mr. Holland From Catherine Dr. Burns would like to have your opinion on an appointment with Mr. Rogers and Mr. Alexander. Haushore READ by a/9 FORD & LIBRARY GERALD General GON Gerald R. Ford Presidential Materials Project Services National Archives and 326 E. Hoover Street Administration Records Service Ann Arbor, MI 48109