The following year, the Bank Committee were still seeking to open a Special Investment Department. The Bank's General Purposes Sub-Committee (at its meeting on January 20th 1930) reported that:

the question arises as to whether or not a further effort should be made to secure amendment of the Regulations to enable the Bank to allow a higher rate of interest on fixed deposits and to impose a larger notice of withdrawal in such cases. On the last occasion when this matter was before HM Treasury, the Chairman was informed that consent could not be given to a higher rate of interest than 3½ per cent owing to the position of the reserve fund, and it was further stated that before any Trustee Savings Bank was authorised to pay a higher rate than that allowed in the ordinary department; viz, 2½ per cent, such Bank had to comply with certain standards laid down regarding the financial position. Subsequently, HM Treasury stated these to be (1) that the special investment department must have a reserve of about 5 per cent of its deposits, and (2) that if the reserve was substantially less than that percentage, the Trustees must be able to point to earnings of about 4½ per cent net on deposits after attributing a fair share of management expenses to the running of the department.

While the necessity for having a reasonable reserve fund cannot be questioned, there is a great difference between this and Trustee Savings Banks so far as HM Treasury is concerned. In the case of a Trustee Savings Bank the Government have a financial responsibility, but in respect of this the financial responsibility is upon the Corporation.

It was decided that the Chairman, with the Town Clerk, City Treasurer and General Manager, be authorised to:

approach HM Treasury with a view to a further endeavour being made to secure power under the Regulations to allow a higher rate of interest on stipulated deposits made for fixed periods and to require longer notice of withdrawal in such cases.

The following related matters were also discussed:

(a)      That confusion arises in consequence of the amendments of the regulations already sanctioned by HM Treasury in 1928 and 1929 being shown separately from the 1925 Regulations.

(b)       That it is necessary for further amendments to be made consequent upon the passing of the Birmingham Corporation (General Powers) Act, 1929; and

(c)       That the stock of printed Regulations is practically exhausted.

The Treasury having expressed their willingness to approve the consolidation of the Regulations [item (a) above], and having also given their tentative approval to new and amended regulations rendered necessary by the Birmingham Corporation (General Powers) Act, 1929 [item (b) above], the Committee proceeded on the basis that a wholesale review of the Regulations was advisable.

The Birmingham Corporation (General Powers) Act, 1929 empowered the Committee to open branches in areas adjoining the City, at the request, or with the approval, of the local authority concerned, and also to make advances to depositors for the purchase of allotments.

A further complication had, however, arisen owing to the fact that the Treasury had issued a new Savings Bank Order and a new set of Regulations for TSBs. Some of the clauses in the Order and Regulations were desirable so far as the BMB was concerned, and as the representatives of the Treasury had intimated to the Chairman on the occasion of his last interview with them that they would be prepared to grant to the Bank any powers which may be granted to TSBs, it was desired to take advantage of the opportunity and introduce the necessary amendments so that when the consolidated regulations were finally approved, such amendments would be included.

The principal alterations were:

Regulation 7. Objects of the Bank.

Clause (b) to be extended so as to provide for advancing money on a dwellinghouse situate in the area of an adjoining local authority, and a new clause to be added to provide for advancing money for the purchase of an allotment within the City of Birmingham or within the area of an adjoining local authority.

Regulation 9. Powers and duties of the Committee of Management.

The second clause in this Regulation provided for the safe custody of money, deeds, etc, belonging to the Bank, and the Committee wished to sanction the introduction of words to cover the acceptance for safe custody of similar documents, securities, etc, belonging to depositors; also to provide for the Bank to make suitable charges to depositors for such convenience. This revision seems to have been to meet the requests of depositors to place items in branch strongrooms, but the words that were eventually added ("and may in their discretion provide for the safe custody of deeds, documents and other securities belonging to depositors, charging a fee therefor") would prove advantageous when the Safe Deposit facility was provided at the new Head Office in Broad Street.

Regulation 13. Offices and Branches.

This Regulation required the Bank Committee to obtain the City Council's approval to purchase or erect premises. An amendment was required to bring the Bank into line with the Trading Committees of the Corporation and to dispense with this requirement. However, the Regulation was not changed on this occasion.

Regulation 20. Stamp Duty.

The existing Regulation stated that no stamp duty was payable on a vacating receipt given under the Building Societies Act, 1874. A change in the Stamp Duty law that required mortgagors to pay stamp duty on vacating receipts necessitated a deletion of the reference to the previous exemption.

Regulation 22. By whom deposits may be made   and

Regulation 37. Exception to limitation of deposits.

The new Savings Bank Order provided for exemption from limitation on the amount of annual deposits to two classes which were not provided for in the regulations of the Bank, the exceptions reading as follows:

with the approval of the Postmaster-General and subject to such conditions as he may require, by a responsible officer of any Government Department or office in his official capacity;

by virtue of or in pursuance of any enactment in that behalf, by the registrar of a county court in England, a sheriff clerk in Scotland or a clerk of the Crown and Peace in Northern Ireland.

It was proposed to add these two unusual categories to the exceptions in the BMB's Regulation No 37 as clauses (f) and (g) but this did not transpire.

Regulation No 32 Pass Books.

This regulation provided that "two or more officers of the Bank shall be parties to every transaction of the depositor, so as to form a double check on every such transaction". The Committee were concerned that the legal interpretation of the words "be parties to" could create difficulty. As the actual practice was for the depositor to be dealt with by the cashier only, and the deposit slip or withdrawal receipt which the depositor had completed and signed was dealt with by the cashier and subsequently by the ledger clerk, it was proposed that the regulation was changed to " two or more officers of the Bank shall deal with every transaction of the depositor, so as to form a double check on every such transaction". It was felt that the new words (which were agreed) would fully cover the routine which is now observed.

Regulation 71. Investment of funds.

Despite the Treasury's previous insistence on the Bank's investments being highly liquid, this Regulation was amended to enable the Bank to invest such portion of its funds as may be thought desirable in Government securities maturing at a date not later than 20 years from the date of investment. This major concession was a consequence of the Savings Bank Act, 1929, which allowed up to 20% of a TSB's special investment department to be invested thus. Confusingly, the Treasury was still not prepared for the BMB to open a special investment department. 

Regulation 72. Audit of Accounts.

Words were added so as to cover the audit of the books and accounts of the Allotment Purchase Department as well as the House Purchase Department, although the Bank did not yet have an Allotment Purchase Department.

Regulation 73. Annual report and statement of account.

Under this regulation every depositor was entitled to receive a printed copy of the annual report and statement of account. It had never been the practice of the Bank to print sufficient copies for every single depositor on the basis that it would be most unlikely that every depositor would wish to exercise their right to have a copy. As, in previous years considerable quantities had been left on hand at the end of the year, it was proposed to substitute "every depositor shall be entitled to a copy" for "every depositor shall be entitled to receive a printed copy"

Regulation 77. Extent of advance to be made.

The existing Regulation gave the Committee of Managementthe right to determine to what extent an advance may be made.

However, the policy of the Committee was to limit loans on the basis of 80 per cent of the valuation (the limit quoted in the existing Regulation), but building societies were making larger advances, and it was wished to have absolute freedom in this regard. The revised Regulation substituted 90% for 80% but still retained the words that enabled the Committee to vary the amount or period in special cases.

Regulation 78. Valuation of property.

It was suggested that the reference to payment of the valuation fee by the depositor be deleted. If this was adopted it was proposed that the Committee would pass a resolution providing for the return of the fee of 10/- deposited with the application form when the Mortgage was entered into, but that in the event of the cancellation of the application, the fee would be retained by the Bank. In the event, the wording of the Regulation was not amended, but this would not stop the Committee instituting its new policy and thus preventing 'dummy' applications being submitted merely to obtain a free valuation.

Regulation 82. Interest on advances.

The existing regulation specified that the rate of interest be charged at a "rate per pound per month" which was simple when the calculation was " one penny per pound per month" (ie 5%) as at the Bank's commencement. Any variation from that rate produced confusion (eg: a rate of one penny farthing per pound per month). The revised Regulation removed the specified method of charging by merely stating "at such rate as the Committee of Management may from time to time determine".

Regulation 85. Insurance.

With loans also to be made for the purchase of allotments, it was necessary to state that property to be mortgaged to the Bank (and thus having to be insured under this Regulation) would be restricted to houses only - this was simply done by adding the word "house" prior to "property".

Regulation 89. Power of inspecting.

For the same reason as amending Regulation 85, in respect of allotments, it was necessary to amend the Power of Inspection by inserting the words "or allotment".

The Committee were unsuccessful in persuading the Treasury to allow the Bank to have a special investment department, and it was decided not to pursue the matter when there was the possibility that such persistence would risk losing agreement to the above Regulation amendments.

The Savings Bank Act, 1929, made it easier to start a new Trustee Savings Bank, and it was made permissible for such new banks to open special investment departments from the first, despite the fact that previously a minimum of £200,000 deposits in the Ordinary Department had been regarded as an indispensable preliminary to such action.

Additionally, it was not possible to get an agreement to amend Regulation 81. Prior Mortgage. Repeated applications were being made to the Bank to take over existing Mortgages with Building Societies and others, but the Town Clerk had advised that the Regulations as at present drawn precluded arrangements being made to take over such mortgages, the applicant having already purchased or acquired the property. No amendment to this Regulation was permitted.

Many of the Treasury's objections were initially based on their view that it was not a good time to amend the Regulations when there was a proposal before the Government to open a Municipal Bank in Cardiff. However, the bid by Cardiff did not succeed.

The City Council approved of the Bank's proposed amendments on June 3rd 1930 after being advised of the various changes and informed that:

At the present times the regulations of the Bank are those of 1925, supplemented by amendments in 1928 and 1929, and as further amendments are necessitated, HM Treasury have concurred in the proposal to consolidate the whole of the regulations into a new set to be known as The Birmingham Municipal Bank Regulations, 1930.

The Town Clerk reported on July 3rd 1930:

Birmingham Municipal Bank Regulations, 1930.

I beg to report that I have now duly received the approval of the Lords' Commissioners of HM Treasury and of the Chief Registrar of Friendly Societies to the Birmingham Municipal Bank Regulations, 1930. The Regulations came into operation on the 1st July instant.

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