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RULES & REGULATIONS
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On October 20th 1930, the Committee instructed the Town Clerk and General Manager to place before the General Purposes Sub-Committee particulars as to the position regarding the following matters:

 

(a) The limitation of deposits, and

 

(b) The establishment of a Special Investment Department.

 

The Town Clerk accordingly prepared a report in conjunction with the General Manager, which

recommend that, so far as the limitation of deposits is concerned, the Town Clerk be instructed to make application to HM Treasury for sanction to deposits being accepted up to £1,000 in any one year in place of the existing limitation of £500.

 

The Town Clerk and General Manager were encouraged to make the application after being informed that notices had been seen in the Salop and Welshpool Trustee Savings Bank stating that the minimum of £500 for deposits per year had been increased to £1,000, and the rate of interest on deposits in the special investment department would be 4% as from November.

 

On the question of the establishment of a special investment department, however, the Sub-Committee felt that having regard to the current position of the money market it would be inadvisable to raise the matter with the Treasury at the present time, and they did not recommend that any action be taken at this stage, and this recommendation was conveyed to Bank Committee on January 12th 1931.

 

Subsequently, the Town Clerk reported on  February 14th 1931, attaching a letter he had received from the Treasury dated February 6th.

 

February 14th 1931

Minute No 3954

Birmingham Municipal Bank Regulations, 1930.

Limit of Deposits.

 

Upon this minute I beg to report that I have duly made application to the Lords' Commissioners of HM Treasury in the matter of the desired amendment of Regulation No 36 so as to enable the Bank to accept deposits in an account up to £1,000 in any one year.

 

I have received a letter in reply from Mr Phillips, of the Treasury, and submit a copy of that letter with this report. No doubt your Committee will wish the matter to be pressed further at a personal interview at the Treasury, and I shall be glad to have your instructions.

 

Treasury Chambers,

Whitehall, SW1.

6th February, 1931.

 

Dear Mr Wiltshire,

 

We have considered your official letter of the 23rd January 1931 proposing that  the annual limit of deposits in the Birmingham Municipal Bank should be increased from £500 to £1,000. We shall of course be happy to discuss the matter with representatives of the Council at any convenient time during the week beginning the 16th February, if, on reading what follows, you think that this would be useful.

 

As at present advised it is very unlikely that the Treasury would be able to modify the view which was expressed in my letter of the 26th March, 1929, on a similar proposal. The limitation of annual deposits to £500 applies also to the Post Office and Trustee Savings Banks and was confirmed by Parliament so recently as 1929. There are certain obvious objections from the point of view of Savings Banks to allowing very large deposits since it is by no means so easy for them as for purely commercial concerns to adjust rates of interest speedily to varying conditions, while they are weakened rather than strengthened by receiving large sums at particular times which are likely to be withdrawn later. This seems to be generally recognised everywhere and by comparison with the rules of Savings Banks in the Dominions and foreign countries even our present limit of £500 is extremely high.

 

I hardly think that the recent increase in the limit for a Trustee Savings Bank Special Investment Depositor is in point, as this is of course a total and not an annual limit.

 

Yours sincerely,

(sgd) F. PHILLIPS.

 

The Committee having considered the report and the letter, were of the opinion that the Treasury should be urged to grant the desired concession, and it was therefore decided that the Chairman, with the Town Clerk and General Manager, be authorised to interview representatives of the Treasury on the question. At the same meeting, the Committee agreed to pay £500 towards the expenses incurred by the City Council in promoting the Birmingham Corporation (General Powers) Act, 1929

 

On March 16th 1931, the Committee were informed that the Chairman, with the General Manager and the Deputy Town Clerk, had interviewed Mr Phillips of the Treasury who had promised to bring the matter before the Financial Secretary to HM Treasury and communicate the latter's views. Although the Minute relating to this topic was continued, no further reference was made to the subject at a time when there was a run on the pound, which slid down from $5 to the $3.25 level, which may have persuaded the Committee to drop the matter - a view reinforced when the rate of interest payable on deposits became a more important issue the following year.

 

A special meeting of the Bank Committee was held on July 11th 1932 to discuss the position arising out of the Government's decision to reduce the interest on War Loan from 5% to 3½% and the consequential effect of such reduction upon the Bank. The 5% War Loan of 1917 was a huge bond issue to finance the cost of the War.

 

Regulation 39 (2) specified that "interest shall be allowed on every complete pound deposited at the rate of three pounds ten shillings per centum per annum", while Clause (1) stated that the rate of interest was subject to the approval of the Treasury.

 

After receiving the views of the City Treasurer upon the income which the Bank may expect to receive from moneys placed with the Corporation at call the Committee arrived at the conclusion that it would be necessary to reduce the interest allowed to depositors by ½%, and that the most appropriate time to give effect to this change would be the date fixed for the Government Conversion of the War Loan, viz, 1st December 1932. Accordingly, it was decided to seek the approval of the City Council at its meeting on July 26th, and the Town Clerk was instructed to obtain the approval of the Treasury.

 

It was also decided that notices advising depositors of the projected change should be prepared, and that the General Manager was instructed to arrange for printing and despatch in envelopes bearing a half-penny stamp.

 

The necessity to reduce the rate of interest on deposits was a major blow to the Committee. Ever since the establishment of the Bank in 1919, and even during the existence of the temporary Bank which preceded it, interest on deposits at the rate of 3½% had been paid, but the drop in the yield of its  investments made it impossible to maintain this rate. The irony of the situation was that the War Loan conversion of 1932 was a scheme by Neville Chamberlain (then Chancellor of the Exchequer) to persuade investors to swap their 5% stock for a 3½% issue. Some 90% of the public accepted the deal, for patriotic reasons at a time of the Depression's national crisis, and the Chancellor had succeeded in reducing his interest expenditure by £23 million.

 

The Bank's report to the City Council on July 26th 1932 stated that:

 

the Council will be aware that the Bank is limited in the matter of investments. Under the Regulations deposits can be (1) invested in House Purchase or Allotment Purchase Mortgages; (2) placed on deposit with the Corporation at call; or (3) invested in Government Securities maturing at a date not later than twenty years from the date of the investment. The Committee have found it mutually advantageous to the Bank and to the City to place all available funds (apart from House Purchase and Allotment Purchase Advances, and cash in hand to meet the exigencies of the Bank) with Corporation at call.

 

Your Committee have gone very carefully into the matter with the Treasurer, and have come to the conclusion that the yield from avenues open for investment of Bank funds will not now admit of a higher rate than 3 per cent being allowed on deposits, and they have therefore to recommend the Council to approve of Bank Regulation No 39 (2) being amended (subject to the approval of HM Treasury and the Chief Registrar of Friendly Societies) as follows:

 

"Interest shall be allowed on every complete pound deposited at the rate of three pounds per centum per annum."

 

It is further proposed to bring such new rate into effect on and after the 1st December, 1932, which coincides with the date fixed by the Government for the 3½ per cent Conversion Loan to supersede the 5 per cent War Loan.

 

The new Regulation also came into force on December 1st 1932 as the Birmingham Municipal Regulations, 1932

 

As this minor text amendment was the only change to be made to the existing printed copies of the Regulations, an appropriately worded rubber stamp was applied adjacent to Regulation 39.

The rubber stamp was also placed in passbooks as they too quoted the interest rate. Thus depositors, having already received a direct communication,  were comprehensively informed of the reduction in the rate of interest. No publicity was given to the fact in the Annual Reports for the period, though the 1933 accounts stated that the rate was 3%.

 

At this period in time, the method of  calculating interest came under scrutiny, probably following a letter to the Birmingham Mail from a depositor. Clarification of the method was subsequently printed in passbooks and in the Regulations booklet.

 

In the period 1931 to 1933, the average yield on the cash placed with the City fell by 1.3 percentage points, and the average rate paid to depositors fell by 0.5 percentage points. However, total deposits increased by £3.4 million.
 

The rate charged on Mortgages was reduced from 5% to 4½ % on February 18th 1935.

 

In October 1934, the Bank Committee considered extensive amendments to the Regulations (some 18 Regulations were listed) as prepared by the Town Clerk, although these were generally of a minor nature, the proposed change to Regulation 39 (Interest on deposits) was significant. The reduction in the rate of interest in 1932 had required a notification being posted to each depositor. It was now proposed that the Regulation should have the following first paragraph:

 

Interest shall be allowed on every complete pound deposited at such rate as the Committee of Management, with the approval of the Treasury, may determine. Such rate shall not be varied by the Corporation except after giving three months' notice to depositors by exhibiting the same in every office of the Bank and by publishing the same at least once in one or more local newspapers circulating in the areas of the Bank's operations.

The new wording, therefore, did not quote a specific rate of interest and allowed that placing notices of a change in all branches (and in local newspapers) was sufficient means of communication.

 

Two amendments were proposed for Regulation 32 (Pass Books). These removed the requirement for depositors to produce their passbook at the Bank at least once a year (a totally impracticable condition, and that

 

Each pass book shall be the property of the Corporation, and shall be delivered up as and when required by the Committee of Management.

 

This was a step towards the Committee's objective of obtaining mutilated passbooks. The objective was to be reinforced by adding the following to Regulation 33 (Lost Pass Books):

 

If, in the opinion of the Committee of Management, any pass book has been tempered with or is in such condition as to render the issue of a new pass book desirable, the Committee of Management may, if they think fit, require the surrender & cancellation of such book and issue the new book to the depositor and charge therefor such sum (not exceeding ten shillings) as they may determine.

 

It was also proposed to add and the Trustee Savings Banks (Special Investments) Act 1934 to Regulation 71 (Investment of Funds) presumably as part of the Committee's desire to have a Special Investment Department.

 

The Town Clerk was instructed to circulate the draft revisions to the members of the Committee for further consideration at a special meeting to be held on October 29th 1934, prior to submitting the amendments to the Treasury and Chief Registrar of Friendly Societies for provisional approval prior to their submission being made formally by the City Council.

 

However, the special meeting called for October 29th never took place and the subject did not arise again until the Finance & General Purposes Sub-Committee reported on February 21st 1938:

 

Proposed Amendment of Regulations

 

Your Sub-Committee report that the Chairman, the Chairman of the General Committee and the General Manager have discussed with the Town Clerk the proposal to amend the Regulations. After considering his views, and learning that the Trustee Savings Banks and the Post Office Savings Banks are contemplating amendments to their powers and Regulations, your Sub-Committee do not recommend any action being taken by the Bank at the present time.

 

A special committee of the TSB Association had been set up to discuss the introduction of new services and to enable the Banks to keep up to date with modern requirements. Apparently, a Bill was drafted but the threat of the Second World War caused abandonment - an attitude reflected in the recommendation of the Finance & General Purposes Sub-Committee.

 

Future amendments of the Regulations were based on the 1930 edition, as follows:

 

Birmingham Municipal Bank Regulations, 1941

 

Regulation 71 (Investment of Funds)

 

Investments in Government Securities were limited by the 1930 Regulations to those maturing at a date not later than 20 years from the date of investment. The only avenue open for such investments was 2½% National War Bonds, 1946/48. On the 1st January, 1941, however, the Government introduced an issue of 3% Savings Bonds, 1955/65, which the Committee thought should be available to the Bank. An amendment was agreed by the authorities to the final part of the Regulation with effect from April 1st 1941:

 

.... or invested in Government Securities at a date not later than twenty thirty years from the date of investment.

 

Birmingham Municipal Bank (Procedure) Regulations, 1946

 

The Corporation's requirement (under Regulation 39 (1)) to give three months' notice to depositors to vary the rate of interest on deposits was amended by the addition of a new Regulation, 39 (4), which required that any notice …. to be given …. may be given by them by advertisement in a daily London newspaper, in a newspaper circulating in the district in which the Bank is situate, and by displaying the same in some prominent position in the buildings in which the business of the Bank is carried on.

 

The Regulation came into force on April 1st 1946.

 

Birmingham Municipal Bank Regulations, 1946

 

This set of Regulations also came into force on April 1st 1946 and amended Regulation 36 (Limitation on the Amount of Annual Deposits and on Deposits in the Aggregate) and Regulation 39 (Interest on Deposits)

 

    - imposed an annual limit of £500 on deposits;

 

    - imposed an aggregate limit of £2,000 on deposits;

 

    - reduced the Rate of Interest on Deposits from 3% to 2¾% with effect from July 1st 1946.

 

This rate of interest remained unchanged until April 1st 1965.

 

 

Birmingham Municipal Bank Regulations, 1947

 

Commencement Date: April 1st 1947

 

Regulations 36 (Limitation on the Amount of Annual Deposits and on Deposits in the Aggregate) and 37 (Exceptions to Limitation of Deposits) were amended so as to define the way in which the limits imposed by the 1946 Regulations would apply.

The principal effects were:

(a)  To maintain the existing limits of £2,000 on aggregate deposits and £500 on annual deposits, but restoring the proviso that a depositor may, not more than once in the same year, deposit money to replace money previously withdrawn in one entire sum during that year.

(b)  To define the conditions under which the limits shall not prevent the making of certain classes of deposits.

(c)  To define certain kinds of deposits which are to be ignored in computing the amount of the account for the purpose of the annual or the aggregate limit.

(d)  To define the classes of depositors to whom limits may not apply, subject to the approval of the National Debt Commissioners.

 

Birmingham Municipal Bank Regulations, 1949

 

Commencement Date: March 9th 1949

 

By this amendment, Regulation 71 (Investment of Funds - that permitted investments in Government Securities), was extended to allow investment in securities of the British Government or in securities guaranteed as to principal and interest by the British Government.

 

Birmingham Municipal Bank Regulations, 1952

 

Commencement Date: March 11th 1952

 

Regulation 36 (Limitation on the Amount of Annual Deposits and on Deposits in the Aggregate)

 

The maximum limit for Deposits was increased from £2,000 to £3,000

 

 

 

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