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Regulatory Reform Issue [1981] (6)
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Regulatory Reform Issue [1981] (6)
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[CoNtinued from previous Folden]
2
THE WASHINGTON POST
April 9, 1981
Help for the Auto Industry
B
Y RELAXING some of the automobile regula-
The basic health and safety standards for the au-
tions, the Reagan administration is offering the
tomobile industry have been set by Congress, and
right kind of help to an industry in trouble. The gov-
only Congress can change them. Within limits that
ernment has given away nothing important to health
Congress has established, the administration has
and safety. Some of the abandoned regulations were
now slightly loosened some of the auto exhaust
marginal, and some were the sort that bring regula-
pollution requirements. Almost everywhere, air qual-
tion into disrepute. Do you really think that federal
ity will continue to improve as more of the new and
law ought to require a tire pressure indicator on the
cleaner cars come onto the road each year. Ten years'
dashboard? If drivers want to save a little money,
experience with automobile pollution leads to a gen-
ought they not have the option of simply looking at
eral conclusion that the present set of rules is prob-
the tires?
ably tighter than it needs to be. The administration's
There's to be a year's delay in the rule requiring
decisions here do not signal a retreat from the na-
automatic devices to protect people in head-on
tional commitment to cleaner air.
crashes. That would mean the famous air bag or, for
The consideration of these regulations has a cer-
most cars, self-locking seat belts. The whole reason
tain relationship to the maneuvering over Japa-
for the rule was to force safety onto those people who
nese imports. Quotas on imports would be a disas-
refuse to buckle their present seat belts. In auto safe-
trous mistake, and, to its credit, the White House
ty, the government's responsibility is clearest
in
seems deeply reluctant to move in that direction.
those matters that buyers and drivers cannot possi-
By far the wisest policy-and the best for the in-
bly judge for themselves. One example is the car's
dustry-is to keep competition open but, at the
gasoline tank, and whether it will rupture in a colli-
same time, get rid of those rules that can be lifted
sion: But where a driver is offered protection like a
without jeopardizing the public's health and safe-
seat belt, and voluntarily rejects it, the government's
ty. That, so far, is what the Reagan administration
duty to impose it willy-nilly is less obvious.
seems to be doing.
3
STATEMENT OF JAMES C. MILLER III
ADMINISTRATOR FOR INFORMATION AND REGULATORY AFFAIRS
OFFICE OF MANAGEMENT AND BUDGET
AND
EXECUTIVE DIRECTOR
PRESIDENTIAL TASK FORCE ON REGULATORY RELIEF
BEFORE THE CONSUMER SUBCOMMITTEE OF THE
SENATE COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION
APRIL 7, 1981
Mr. Chairman and Members of the Committee:
I welcome this opportunity to discuss reauthorization
of the Consumer Product Safety Commission (CPSC).
The Administration's views on the CPSC are those implied
in the recent budget submission and those explicitly stated
in Director Stockman's testimony before the House Subcommittee
on Commerce, Consumer and Monetary Affairs dated March 16,
1981. Additional information is contained in a document
which the Office of Management and Budget is releasing
today, the relevant portions of which are attached.
As you know, the Administration has proposed a $12
million (27 percent) reduction in the CPSC's budget authority.
It has taken this action for two reasons: first, because
this lower level of funding is the amount the Administration
2
feels is needed for the CPSC to meet its statutory responsibilities;
and second, because the Administration believes that if
funded at a higher level, the CPSC would likely use the
funds to embark on activities beyond its statutory mandate
or where other agencies of the government could accomplish
these tasks more efficiently.
In support of the Administration's position on the
CPSC, today I would like to outline briefly two principles
underlying sound regulatory policy that the Committee may
wish to address before drawing conclusions about reauthorization.
One principle is that government should intervene only
when there is clear evidence that the unregulated market is
not working well. Moreover, since government regulation by
its very nature is fraught with imperfections, we must be
careful to avoid comparing imperfectly functioning actual
markets and idealized systems of regulation. Thus, a cogent
argument for government intervention requires not only a
demonstration that the market fails but that regulation
would lead to a superior outcome.
A second principle of sound regulatory policy is that
in contemplating government intervention we should be mindful
that a variety of regulatory mechanisms are available. In
the area of consumer product safety, for example, there are
instances where markets could be made to work better if more
information were provided. Educating consumers about potential
hazards may be far more effective in reducing accidents --
and far less costly to society -- than promulgating mandatory
3
product standards. For instance, warning consumers not to
stick their hands or feet under a power lawnmower while it
is running may be more desirable than setting mandatory
standards detailing how lawnmowers should be designed so as
to prevent injuries. Such mandatory standards create incentives
for consumers to defeat safety devices and impose on them
higher prices and reduced availability of the regulated
products.
These principles are more easily stated than implemented,
especially in the context of authorizing legislation. I
think casual observation would suggest there are consumer
product areas in which some form of government intervention
is warranted. However, I feel that in many, if not most,
cases such intervention should be in the form of providing
information rather than promulgating specific standards.
I hope these views will prove helpful to the Committee
as it considers the CPSC's future. I would be pleased to
respond to any questions you might have.
FISCAL YEAR 1982
Budget Revisions
Additional Details
on Budget Savings
PREMIUM THE 40 OF THE OF OFFICE UNITED OFFICE Bunder CANADA CUTTER STATES OF AND GREAT
APRIL 1981
EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
Consumer Product Safety Commission
Agency: Consumer Product
Functional
Budget Reform
Safety Commission
Code: 554
Criterion: 6
Funding
($ in millions)
1981
1982
1983
1984
1985
1986
CARTER BUDGET:
Budger Authority
44
45
45
45
45
45
Outlays
44
47
45
45
45
45
REESTIMATES & ADJUSTMENT:
Budget Authority
Outlays
PROGRAM CHANGES:
Budget Authority
-2
-12
-12
-12
-12
-12
Outlays
-2
-12
-12
-12
-12
-12
REAGAN BLDGET:
Budget Authority
42
33
33
33
33
33
Outlays
42
35
33
33
33
33
Program Description
CPSC identifies unreasonable hazards associated with consumer products and seeks to control them
through education of consumers, obtaining voluntary changes in production by manufacturers or,
when necessary, promulgation and enforcement of rules regulating or banning hazardous products.
Proposed Changes
Budget authority and outlays are proposed to be decreased by $2 million in 1981 and $12 million in
1982 through selected reductions in field activities, modifying the hospital-based acute injury
surveillance systems, limiting expansion in chronic chemical hazard regulation, restricting compliance
and enforcement activities, and increasing efficiency of organization.
Rationale
By cutting back lower-priority activities, this proposal would impose needed fiscal restraint, without
jeopardizing the agency's statutory mission. CPSC's success in recent years in controlling the most
important acute hazards has lessened the need for expensive surveillance activities. Success in
achieving voluntary industry compliance and improved cooperation with State and local consumer
protection agencies means enforcement activities can be limited. Unanswered questions about the
human health impact of chronic chemical exposure indicate a need for more research, not more
regulation, in this area.
Key Facts About the Program
Increased funding will be provided for the HHS National Toxicology Program.
Interagency regulatory coordination for toxic chemicals is provided by the Interagency
Regulatory Liaison Group.
343
4
U.S. REGULATORY COUNCIL
Washington, D.C. 20503
STATEMENT OF PETER J. PETKAS
DIRECTOR, U.S. REGULATORY COUNCIL
BEFORE THE
SUBCOMMITTEE ON H.U.D. AND INDEPENDENT AGENCIES
SENATE COMMITTEE ON APPROPRIATIONS
APRIL 8, 1981
Mr. Chairman and members of the Subcommittee, I am pleased
to be here today to discuss with you the activities of the U.S.
Regulatory Council.
The Council's duties and responsibilities were, until recently,
set out in former President Carter's memorandum of October 31, 1978,
which created the Council (Attachment I). The Council's functions
in that area have now been superseded by the President's Task Force
on Regulatory Relief, chaired by Vice President George Bush.
Generally, the Council was directed to help ensure that
regulations are well coordinated, do not conflict, and do not
impose excess burdens on particular sectors of the public. TO
help achieve these goals, the Council was also asked to publish
the Calendar of Federal Regulations twice a year.
In its two years of existence, the Regulatory Council has
worked to achieve lasting reforms in the regulatory arena. The
tasks were largely unprecedented, so the Council reform efforts
evolved into three major activities:
1. Compiling and distributing information about
new rules the federal government plans to issue.
This includes the Calendar of Federal Regulations
and the Automobile Calendar.
- 2 -
2.- Identifying and promoting effective techniques
for regulating. The innovative techniques
project which induces agencies to adopt
alternatives to traditional command-and-control
regulation is one example; assessing the
analyses of the benefits of regulation in the
non-ferrous metals industry and assisting agencies
to improve regulatory analysis techniques are
others.
3. Addressing specific problems caused by the
diversity of regulatory programs and the lack
of communication among them. Here the Council
worked to solve problems in the coal industry
and in speeding the permits needed to build
certain facilities.
On March 25, 1981, Vice President Bush announced that the
collegial body known as the Regulatory Council would be disbanded,
but that Council staff would continue to work on ongoing projects,
particularly the Calendar of Federal Regulations. In particular,
on March 25, 1981, the Vice President requested all agencies to
continue to cooperate in preparing the Calendar of Federal
Regulations. The Calendar and its related projects will be
continued in 1982 within the Environmental Protection Agency.
Although the heads of the 38 regulatory agencies which
made up the Council will no longer meet as a formal Regulatory
- 3 -
Council, the President's Task Force on Regulatory Relief will
be meeting and will be carrying out the worthwhile efforts of
the Council. In addition to Vice President Bush, Chairman,
the Task Force members are the Secretary of the Treasury, the
Attorney General, the Secretary of Commerce, the Secretary of
Labor, the Director of the Office of Management and Budget, the
Assistant to the President for Policy Development, and the Chairman
of the Council of Economic Advisers. With the creation of the
Task Force on Regulatory Relief and the expanded role for the
Office of Management and Budget under Executive Order 12291 and
the Paperwork Reduction Act (P.L. 96-511), and with the projected
move of the regulatory review staff of the Council on Wage and
Price Stability to OMB, the President felt that a separate
Regulatory Council staff function would not be necessary after
this fiscal year. Thus no funds are requested for FY 82.
This concludes my prepared remarks. I would be happy to
answer any questions you may have at this time.
5
April 10, 1981
REGULATORY ACTION OFFICERS
DEPARTMENT
NAME
PHONE NO.
Agriculture
Miriam Bender
447-3155
Associate General Counsel
Commerce
Edward Wilczynski
377-2938
Richard Herbst
377-2652
Defense
D. O. "Doc" Cooke
695-4436
Arthur Ehlers
695-4278
Education
Thomas C. Anderson
Energy
William Funk
252-6736
Deputy General Counsel
Health and Human
Services
Housing and Urban
Burt Bloomberg
755-7203
Development
Harwood Martin
755-6207
Interior
Timothy Elliott
343-4722
Justice
Labor
Phoebe Marse
523-7701
Assistant to the Solicitor
State
Gladys Poticher
632-7968
Gene Malmborg
632-2350
Transportation
Neil R. Eisner
426-4723
Assistant General Counsel
Treasury
Steven Skancke
566-2269
Executive Secretary
PRESERVATION
Reagan Team: a Regulatory U-Turn
By Ward Sinclair
join a Supreme Court case challenging the constitution-
Washington Post Staff Writer
ality of the strip-mine law he will be sworn to uphold.
Last fall John B. Crowell Jr., chief lawyer for a com-
Robert F. Burford of Colorado, the nominee to run
pany that is the largest buyer of timbering rights in
Interior's Bureau of Land Management. As speaker of
publicly owned national forests, delivered a rousing at-
the Colorado House two years ago, he was a leader in a
tack on federal timber management policies.
legislative effort to legitimize the Sagebrush Rebellion,
Crowell's speech to the Society of American Foresters
which seeks to turn BLM land over to the states. As a
sent shivers through the environmental community, but
cattle rancher, Burford has a permit to graze his stock
it was no surprise. As general counsel for the Louisiana-
on 33,614 acres of public land in Colorado.
Pacific Corp., Crowell was known widely for his antago-
Anne M. Gorsuch of Colorado, the president's
nism toward the U.S. Forest Service.
choice to direct the Environmental Protection Agency.
Today, Crowell is about to take control of the Forest
She is a lawyer and former Republican state legislator.
Service as an assistant secretary of agriculture. His
She and Burford share common bonds - they were
pending nomination by the Reagan White House is one
close political allies in the legislature, remain close
of a number of major appointments that suggest the
friends, are both friends of Interior Secretary James G.
administration intends even more than it has said to
Watt and were both supported for their jobs by conser-
reverse federal environmental policy.
vative Colorado beer brewer Joseph Coors.
Some of the staunchest critics of federal programs in
Ray Arnett of California, the nominee to oversee
their previous private lives are moving into positions of
the Fish and Wildlife Service at Interior. He was state
influence in the government. They include:
fish and game director when Reagan was governor of
James R. Harris of Indiana, Reagan's choice to
California and was scored for positions environmental-
head Interior's Office of Surface Mining. As a state
ists felt to be inimical to game conservation. More re-
senator, he pushed the resolution that led Indiana to
See REGULATORS, A6, Col. 1
A6
Thursday, March 5, 1981
THE WASHINGTON POST
Reagan's Environmental Team Represents a Regulatory U-Turn
REGULATORS, From A1
the nearly finished Law of the Sea.
trol over parks, public lands and wa-
Crowell's celebrated speech, widely
a position to alter the policies that he
ly-subsidized irrigation water to large
cently, as a board member of the Na-
Treaty the administration is trying to
ter, while opening public terrain to
circulated here and across the country
and other conservative state legislators
growers in the West. Officials of the
tional Wildlife Federation, he has
block. Breaux has maintained that the
more mineral exploration and devel-
by environmentalists, criticized Forest
in coal states have fought since a
Farm/Water Alliance, a lobby for big
been involved in a power struggle
treaty would block the access of U.S.
opment.
Service policy limiting the amount of
tough regulatory law was passed in
growers, in a December letter thanked
aimed at ousting executive vice presi-
companies to seabed minerals.
That approach has sharp echoes
old-growth cutting in the Northwest
1977.
Watt for his past help in litigation
dent Thomas Kimball, a favorite of
In each of these instances, the
throughout the administration.
and forest-management rules now.tak-
Both Harris and Watt are in a
aimed at stopping the regulations.
conservationists.
Reagan choices will replace adminis-
Crowell's pending nomination as chief
ing effect at the direction of Congress.
somewhat unusual situation on strip
Interior officials maintained last
trators who generally, although not
overseer of the national forests, in the
On both issues, Crowell will be able
mining. Indiana, at Harris' behest, is
month that Watt's decision did not
Carol E. Dinkins of Texas, the
darlings of the environmental move-
view of environmentalists, follows the
to change the service's direction if he
fighting the strip mine law in the Su-
represent a violation of his promise.
first woman partner in John Con-
ment, at least were regarded as ap-
pattern.
chooses. He also will be in a position
preme Court Watt, as president of
And Farm/Water this week contended
nally's Houston law firm, Vinson &
proachable. For the movement, it is
If nominated and confirmed by the
to carry out policy changes recom-
the Mountain States, Legal Founda-
that its letter to Watt was in error in
Elkins, who is to be assistant attorney
clearly now a new day.
Republican Senate, as is expected,
mended in 1979 by the National For-
tion in Denver, filed a friend-of-the-
attributing legal aid to him.
general for land and natural resources
"The problem is that there's no
Crowell will be in charge of his old
est Products Association legislative
court brief supporting Indiana and
Watt's selection of cattleman Bur-
- the chief federal lawyer on envi-
balance in these appointments," said
nemesis, the U.S. Forest Service, and
subcommittee he headed:
Virginia at the same time he was
ford to head the Bureau of Land
ronmental issues. Much of her work
Brock Evans, of the Washington office
be in a position to alter the policies
Among other things, the association
being selected as interior secretary-
Management, which oversees federal
in Texas involved corporate clients
of the Sierra Club. Added Brant
that govern commercial timber cutting
opposed Forest Service proposals to
designate.
grazing lands in the West, may create
doing battle over federal air and water
Calkin, Sierra's Southwest representa-
on about 90 million acres of national
protect wildlife in the forests through
During his Senate confirmation
similar questions and challenges from
protection laws.
tive in Santa Fe: "There's all this talk
forest land.
regulation of timber clear-cutting and
hearing, Watt promised to "recuse"
environmentalists.
Ted Kronmiller, a House subcom-
of the foxes in the henhouse. Well, it
The Sierra Club, the Wilderness
to protect streams by requiring com-
himself from decisions that might af-
Burford has been quoted as saying
mittee staff aide who is reported to be
may be more like asking Dracula to
Society and the Natural Resources
panies to leave uncut buffer zones of
fect companies or individuals that had
that he intends to seek transfer of his
guard the blood bank."
Defense Council intend to oppose
timber along the banks. The associa-
provided financial support to Moun-
permit to graze his stock on BLM
in line to become deputy assistant
Through a series of statements and
Crowell's nomination on the ground
tion lost on both points, but, as Bar-
tain States, or in which his foundation
lands near Grand Junction, Colo., to
secretary of state for oceans and fish-
actions, Interior Secretary Watt has
that it raises conflict-of-interest ques-
low noted, it is a new day at the For-
had been involved.
one of his sons. A BLM spokesman at
eries. He has been an assistant to
left no doubt about the environmental
tions. But, having seen the sunrise of
est Service.
Last month, however, Watt an-
Grand Junction, however, said yester-
Rep. John Breaux (D-La.), perhaps
direction of the administration. His
the new day, they don't expect to
At Interior, Harris, the new head of
nounced he was suspending regulatory
day that the office has not received a
the leading congressional opponent of
aim is to reduce his department's con-
have much impact.
the strip-mine control office, will be in
actions on the distribution of federal-
transfer application from Burford.
JAB
OMB LIST OF REGULATIONS WHICH CAN BE WITHDRAWN IN THE NEXT SIX WEEKS
I had this
pulled from the
overall OMB
DEPARTMENT OF AGRICULTURE
list
Trach
Stage
Costs (millions)
of
Agency
One-Time
Recurring
Economic Sectors
Proposed
Title and description of regulation
Development
Discretion
(or Investment)
(or Annual)
Affected
Target
MPT
me hened
2/14-
work Registration and Job Search.
NPRM
Some
?
$95
States
would require able-bodied food
Food Stamp
stamp recipients to interview for
recipients
at least 24 job opportunities
File
identified by state employment
security agencies.
Reg
Reforms
National School Lunch Pattern
Very early
Total
?
$2
State school food
Monitoring. Would establish
authorities
procedures for monitoring the
Local schools
quantity and quality of school
lunch food components.
Agricultural Foreign Investment
NPRM
Some
?
?
Foreign individuals
Disclosure. Rules require foreign
and entities
owners of U.S. agricultural land to
disclose and describe land holdings.
-2-
DEPARTMENT OF ENERGY
Stage
Costs (millions)
of
Agency
One-Time
Recurring
Economic Sectors
Proposed
Title and description of regulation
Development
Discretion
(or Investment)
(or Annual)
Affected
Target
Energy Efficiency Standards for
NPRM
Some
?
?
Five Types of Consumer Products.
Appliance
X
manufacturers
Would set standards for humidifiers/
dehumidifiers, clothes washers, television
sets, dishwashers, and heat pumps.
DEPARTMENT OF HEALTH AND HUMAN SERVICES
-5-
Stage
Costs (millions)
of
Agency
One-Time
Recurring
Economic Sectors
Proposed
Title and description of regulation
Development
Discretion
(or Investment)
(or Annual)
Affected
Target
Prospective Rates for Outpatient
NPRM
Some
Kidney Dialysis. Would set up a new
0
0
Hospitals and
X
reimbursement scheme for costs of
other dialysis
outpatient dialysis.
providers
Sprinkler Systems. Would require
NPRM
sprinkler systems in newly-constructed
Total
$15
?
Nursing homes
nursing homes.
X
Adoption Assistance and Child
ANPRM
Some
?
?
State welfare
X
welfare. Would require state welfare
agencies
agencies to provide some uniform
services, such as financial assistance
to families adopting children with
special needs.
Intermediate Care Facilities
for Mentally Retarded.
Final
Some
?
?
States and
These rules set treatment and physical
Mental health
X
plant standards for intermediate care
facilities
facilities for the mentally retarded.
1
-6-
DEPARTMENT OF LABOR
Stage
Costs (millions)
of
Agency
One-Time
Recurring
Economic Sectors
Proposed
Title and description of regulation
Development
Discretion
(or Investment)
(or Annual)
Affected
Target
Airline Employee Protection Program.
NPRM
Some
?
?
Airlines
X
would give laid-off airline employees
first right of hire at all other
airlines.
Davis-Bacon. Rules requires
NPRM
Total
?
?
Federal construction
X
Federal construction contractors
contractors
to pay certain rates to their
employees. The rates are largely
based on union contract rates.
-7-
DEPARTMENT OF TRANSPORTATION
Stage
Costs (millions)
of
Agency
One-Time
Recurring
Economic Sectors
Proposed
Title and description of regulation
Development
Discretion
(or Investment)
(or Annual)
Affected
Target
Passenger Auto Fuel Economy
NPRM
Total
?
$10
Auto industry
X
Rulemaking. Would set higher fuel
Related industries
economy standards for passenger
Consumers
cars in Model Year 1985 and later.
Pedestrian Protection. Would
Very early
Total
?
$400
Auto industry
X
reduce pedestrian injuries through
Pedestrians
mandatory redesign of auto bumper,
grill and hoods.
File
SUBJECT: Standards for Factual and Legal Conclusions Supporting
Proposed Regulations for Possible Inclusion in
Executive Order on Regulations
BACKGROUND
One of the issues included in prior regulatory reform debates
has been the applicable standards for factual and legal deter-
minations underlying regulations. This has usually been framed
in the context of standards for judicial review of regulations.
Under existing law and judicial precedents, agency legal inter-
pretations are given an assumption of validity, in effect giving
the challenger the burden of proof that the regulations exceed
the agency's legal authority. Also, agency factual conclusions
(such as regarding the nature of the problem addressed by the
regulations) are generally accepted without much scrutiny of the
evidence submitted. Higher judicial review standards to scrutin-
ize both the agency's legal authority and its factual conclusions
have been proposed, such as in the Bumpers Amendment (passed by
the Senate in 1980) and in a new Bumpers/Laxalt bill this year.
POSSIBLE STANDARD FOR INCLUSION IN EXECUTIVE ORDER
Before approving any proposed regulation, the Department or
agency head must:
(1) make a specific finding, supported by a memorandum of
law, that the regulation is clearly within the authority
delegated by law and consistent with Congressional
intent; and
(2) make a specific finding that factual conclusions upon
which the regulation is based are supported by substan-
tial evidence in the agency record taken as a whole,
including comments submitted by the public, particularly
members of the public required to comply with the
regulations.
12/4 margaret:
mil thankyou
The
unecessary regula
tion should be clim.
Savings
inated RR
Bank
believer
SHERWOOD W. TRAVERS
President and Treasurer
Reg.Retorm File
November 21, 1980
Mr. James Baker
c/o The Republican National Committee
310 First Street S.E.
Washington, D. C. 20003
Dear Mr. Baker:
The theme of this letter is less government.
The Savings Bank of Ansonia is a $194 million mutual savings bank.
We have total deposits of $170 million. In our fiscal year ending
May 31, 1980, our net operating earnings were $1,944,000. Because of
the increase in interest rates which occurred in the spring of last year
and which is recurring now, I am forecasting a net operating income of
about $1,100,000 for our year ending next May 31. 72% of our assets are
invested in residential mortgage loans mainly in the 1 to 4 family
category. We are faced with a sharply decreasing earnings because of
the high cost of deposits and we must do everything we can to control
our operating costs.
In March of 1980 the Congress passed the Depository Institutions
Deregulation and Monetary Control Act. Under this regulation, we are
required to maintain daily deposit statistics reporting them weekly to
the Federal Reserve Bank of Boston and maintain certain reserves in our
vault or on deposit with that bank.
Enclosed you will find a copy of the first such report we received
from the Federal Reserve Bank of Boston. Our statistics are submitted
to them as of Thursday of each week. They must then keypunch all of
this information for every bank in New England and mail us back a report.
You will note that to prepare this report, we must research 17 separate
statistical totals for every day of every week, for every week of every
month from now on. You will note that the total of our net transactions
accounts as shown on page 2 of this report is $3,484,000. The total of
our non-personal savings deposits is $2,721,000, therefore our reserve
requirements are calculated on $6,205,000. Page 3 of this report reveals
that we must maintain total adjusted reserves of $23,000. The next line
of this reserve shows that we have cash in our vaults of $908,000. In
other words, we have an excess reserve position of $885,000.
The Savings Bank of Ansonia
211 Main Street
Ansonia, Connecticut 06401
734-2561
Mr. James Baker
November 21, 1980
c/o The Republican National Committee
Page Two
The ridiculousness of this regulation and the cost to us of complying
with it is illustrated by the fact that our total transaction deposits,
if related to MB1 is expressed as the following amount .000000015.
Since the regulation was passed, we have been required to expend
over $900 in sending our officers to New York and Boston to attend
seminars with the Federal Reserve Bank concerning compliance with this
regulation. We now find that we are required to pay our data processing
bureau $35 a month for computer analysis of our deposits to provide the
figures not available to us in our internal files. In addition, we
determine that the internal operating cost of preparing and mailing the
report becomes $16.52 each week.
I fully appreciate the need for the Federal Reserve Bank to monitor
the money supply and I fully appreciate and support the actions of the
Chairman of the Federal Reserve System in attempting to control the
reserve balances of all of our banks. However, I ask that our new
administration review this matter as it has gone past the realm of
reasonableness. To impose on all of the smaller banks in this country
the burden imposed by this new regulation is, in my opinion, ridiculous,
and I ask your support in attempting to make changes in this monstrous
regulation.
Yours very truly,
THE SAVINGS BANK OF ANSONIA
President
SWT:mbp
Enc.
REPORT OF TRANSACTION ACCOUNTS, OTHER DEPOSITS, VAULT CASH,
PAGE
1
AND RESERVE REQUIREMENTS
FEDERAL RESERVE BANK OF BOSTON
11/11/80
SAVINGS BANK OF ANSONIA
ABA
BASE
RESERVE
PERIOD ENDED
PERIOD ENDED
ANSONIA, CONN. 06401
2111-7271-4
11/05/80
11/19/80
CLOSE OF
DEMAND DUE
DEMAND DUE
US GOVT
OTHER
ATS
TELEPHONE OR
BUSINESS
TO
TO OTHER
DEMAND
DEMAND
ACCOUNTS
PREAUTHORIZD
DAY DATE
BANKS
INSTITUTIONS
DEPOSITS
DEPOSITS
TRANSFERS
M
T
M
T
P
T
M
T
M
T
M
T
THU
30
42
0
5
3,246
C
1,014
FRI
31
43
0
5
3,933
0
1,039
SAT
01
43
0
5
3,933
0
1,039
SUN
02
43
0
5
3,933
0
1,039
MCN
C3
43
0
7
3,575
0
1,039
TUE
04
46
0
7
3,179
0
1,010
WED
05
52
0
6
2,925
0
1,010
TOTALS
312
0
40
24,724
0
7,190
AVERAGES
45
0
6
3,532
0
1,027
CLOSE
OF NCW ACCOUNTS
TOTAL
DEMAND DUE
CASH ITEMS
OTHER
OTHER
BUSINESS
/SHARE
DRAFT
TRANSACTION
FROM
DEP
IN
SAVINGS
SAVINGS
DAY DATE
DEPOSITS
ACCOUNTS
INSTITUTIONS
PROCESS
PERSONAL
NON-PERSONAL
M
T
M
T
P
T
M
T
M
T
M
T
THU
30
166
4,473
1,022
49
68,309
1,881
FRI
31
170
5,190
1,464
37
68,972
1,883
SAT
01
170
5,190
1,464
37
68,972
1,883
SUN
02
170
5,190
1,464
37
68,972
1,883
MON
03
174
4,838
1,100
4
68,972
1,883
TUE
04
174
4,416
1,274
4
69,240
1,872
.ED
05
172
4,165
1,111
4
69,479
1,879
TOTALS
1,196
33,462
8,899
172
482,916
13,164
AVERAGES
171
4,780
1,271
25
68,988
1,881
CLOSE OF
TOTAL
TIME
TIME
TIME
TOTAL
TIME
BUSINESS
CTHER
DEPOSITS
DEPOSITS
DEPOSITS
TIME
DEPOSITS
DAY DATE
SAVINGS
PERSONAL
NPERS
LT
4YR
NPERS
GE
4YR
DEPOSITS
GT $100000
M
T
M
T
F
T
M
T
F
T
M
T
THU
50
70,190
95,487
837
204
97,028
234
FRI
31
70,855
96,165
340
205
97,210
234
SAT
01
70,855
96,165
840
205
97,210
234
SUN
02
70,855
96,165
840
205
97,210
234
MCN
03
70,855
96,165
340
205
97,210
234
TUE
04
71,112
96,971
340
205
98,016
234
atD
05
71,358
95,884
340
205
96,929
234
TOTALS
496,080
073,502
5,877
1,434
680,813
1,638
AVERAGES
70,869
96,215
340
205
97,259
234
REPORT OF TRANSACTION ACCOUNTS, OTHER DEPOSITS, VAULT CASH,
PAGE 2
AND RESERVE REQUIREMENTS
FEDERAL RESERVE BANK OF BOSTON
11/11/80
SAVINGS BANK OF ANSONIA
ABA
BASE
RESERVE
PERIOD ENDED
PERIOD ENDED
ANSONIA, CONN. 06401
2111-7271-4
11/05/80
11/19/80
CLOSE OF
VAULT
AFFIL OBLIG AFFIL OBLIG AFFIL OBLIG
BUSINESS
CASH
MATURING IN
(PERS) MAT
(NPERS)MAT
DAY DATE
LT
14DAYS
14D
-
4YRS
140
-
4YRS
M.
T
M
T
M
T
M
T
THU 30
1,324
0
0
0
FRI 31
1,012
0
0
0
SAT 01
1,012
0
0
0
SUN 02
1,012
0
0
0
"CN 03
627
0
0
0
TUE 04
436
0
0
0
WED 05
935
0
0
0
TOTALS
6,358
0
0
C
AVERAGES
908
C
0
0
EXPLANATION OF CALCULATIONS
2
M
T
M
T
H
TOTAL TRANSACTION ACCOUNTS
4,780
LESS:DEMAND DUE FROM DEPOSITING INSTITUTIONS
-
1,271
LESS:CASH ITEMS IN PROCESS
-
25
DAILY AVERAGE NET TRANSACTION ACCOUNTS
3,484
3% X(AMOUNT THROUGH 25,000,000 )
104,5
12% X ( AMOUNT OVER 25,000,000 )
0
RESERVE REQUIREMENT ON TRANSACTION ACCOUNTS (PAGE 3, LINE A)
104,5
OTHER SAVINGS NONPERSONAL
1,881
TIME DEPOSITS NONPERSONAL MATURING LESS THAN 4 YEARS
+
840
TOTAL NONPERSONAL
2,721
RESERVE REQUIREMENT ON NONPERSONAL a 3% (PAGE 3, LINE P)
81,6
REPORT OF TRANSACTICN ACCOUNTS, OTHER DEPOSITS, VAULT CASH,
PAGE 3
AND RESERVE REQUIREMENTS
ABA : 2111-7271-4
11/11/80
RESERVE CALCULATIONS
***
M
T
H
***
RESERVES COMPUTED USING RATIOS IN EFFECT CURRENTLY
A
104,5
A
TOTAL FOR NET TRANSACTION ACCOUNTS ,ALL RATIOS
B
81,6 B
TOTAL FOR ALL NON-PERSONAL TIME DEPOSITS
TN
186,1
TN TOTAL RESERVES COMPUTED USING RATIOS IN EFFECT CURRENTLY
***
M
T H ***
EXPLANATION OF ADJUSTMENTS
TN
186,1
TN TOTAL RESERVES COMPUTED USING RATIOS IN EFFECT CURRENTLY
.8750
X
TIMES X APPLIED TO COMPUTE TRANSITIONAL ADJUSTMENT
A1
162,8
A1
TRANSITIONAL ADJUSTMENT
***
M
T H ***
REQUIRED DEPOSIT CALCULATION
TN
186,1
TN
TOTAL RESERVES USING RATIOS IN EFFECT CURRENTLY
-A1
162,8
A1
TRANSITIONAL ADJUSTMENT
TAR
23,0 TAR TOTAL ADJUSTED REQUIRED RESERVE CHUNDREDS TRUNCATED)
-vc
908,0 VC VAULT CASH
NRR
0 NRR NET REQUIRED RESERVES
ANY DISCREPANCY BETWEEN THE FIGURES IN THIS REPORT AND THE RECORDS OF YOUR BANK
SHOULD BE REPORTED TO OUR ACCOUNTING DEPARTMENT TELEPHONE NUMBER 617-973-3008