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AUGUST 6, 1974.

Mr. ALFRED BRITTAIN III,

Bankers Trust Co.,

New York, N.Y.

DEAR MR. CLAUSEN: Enclosed is a copy of "Nominees", a useful reference brochure published by Morgan Guaranty Trust. It indicates to the user the nature of individual nominee accounts (such as trust and investment division, custodial and corporate trust).

A similar list and explanatory remarks (or brochure, if published) from your bank would be useful in our continuing efforts to improve the accuracy of corporate ownership reports filed with Federal regulatory agencies.

Very truly yours,

Enclosure.

(Similar letter sent to 18 banks.)

LEE METCALF.

Hon. LEE METCALF,

U.S. Senate, Russell Senate Office Building,
Washington, D.C.

BANKERS TRUST CO.,

New York, N. Y., October 10, 1974.

DEAR SIR: In response to your request, we are pleased to enclose a list of the Nominee Partnerships presently used by Bankers Trust Company, which also indicates the Department of the Bank using the particular nominee.

Very truly yours,

Enclosure.

RICHARD S. DENNY.

OCTOBER 10, 1974.

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DEAR SENATOR METCALF: Thank you for your letter of August 6 enclosing a copy of Morgan Guaranty's recent brochure on "Nominees". It is certainly informative and obviously makes a contribution to our mutual desire of dispelling any mystery surrounding the mechanical functioning of the securities markets.

As you know, we are in full agreement with this posture. Our approach will be a little different than Morgan's but hopefully just as effective. We are preparing an article for the fall edition of our employee monthly publication. This will fully describe the "Nominee System" and include a list of our own nominees. We will endeavor to obtain maximum public distribution by making reprints available. I will see that a copy of the magazine is forwarded to you as soon as it is off the press.

Sincerely,

WILLIAM I. SPENCER, President.

UNITED STATES TRUST CO., oF NEW YORK,
New York, N.Y., August 15, 1974.

Hon. LEE METCALF,
Chairman, Subcommittee on Budgeting, Management, and Expenditures, Com-
mittee on Government Operations, U.S. Senate, Washington, D.C.

DEAR SENATOR METCALF: Mr. Charles W. Buek, our Chairman of the Board and President, has asked me to forward to you the enclosed list of our nominees, together with the use and nature of the individual nominee accounts.

Thank you for sending us the copy of the Morgan brochure which clearly sets forth the reasons for the use of nominee registration.

Very truly yours,

Enclosure.

LEONARD T. SCULLY,
Senior Vice President.

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THE CHASE MANHATTAN BANK NATIONAL ASSOCIATION,
New York, N.Y., August 22, 1974.

Hon. LEE METCALF,

U.S. Senate, Committee on Government Operations,
Washington, D.C.

DEAR SENATOR. METCALF: Mr. Rockefeller has asked me to reply to your recent request for a listing of nominees used by The Chase Manhattan Bank. While we have not published this information in brochure form, we are pleased to enclose a list of our nominees, which indicates the type of account relationship for which each is utilized.

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All the nominees listed above that appear without an asterisk are nominees of The Chase Manhattan Bank, N.A. The nominees marked with an asterisk are utilized by the following wholly owned subsidiaries of The Chase Manhattan Corporation:

Carn-Kauf & Co.-Chase Manhattan Bank of the Mid-Hudson, N.A. (Saugerties).

Firbankon & Co.-Chase Manhattan Bank of Northern New York, N.A. (Canton).

Pease & Co.-Chase Manhattan Bank of Central New York, N.A. (Syracuse). Andrews & Co.-Utilized by The Chase Manhattan Bank, N.A., London to register U.S. security holdings of its customers.

Chase Nominees, Ltd.-Utilized by The Chase Manhattan Bank, N.A. (London) to register on behalf of its customers securities other than those of U.S. corporations.

The letter appearing to the right of each nominee indicates the type of account that utilizes the nominee.

C.-Custody accounts.

T.-Trust accounts (employee benefit trusts, personal trusts and estates, investment management accounts).

L.—Loan department holdings used as collateral for customers' borrowings. P&D.-Assets held in Chase's own portfolio or assets retained temporarily by the Bank in its capacity as dealer.

CT.-Corporate trust accounts.

FC.-Foreign charitable (Canadian securities purchased by charitable, educational, or non-profit accounts which have been granted exemption from Canadian taxes).

The only category of account where the Bank might have investment or voting discretion would be in the Trust area (coded T). In many instances, however, the Trust customer retains investment and/or voting responsibility for his assets or elects to share such responsibility with the Bank.

NOTE. The only Trust accounts utilizing Cudd & Co. are investment management accounts where the Bank may have investment discretion but never has the authority to vote.

Hon. LEE METCALF,

MANUFACTURERS HANOVER TRUST Co.,
New York, N.Y., August 21, 1974.

Chairman, Subcommittee on Government Operations,
U.S. Senate, Washington, D.C.

DEAR SENATOR METCALF: Our Chairman, Mr. Gabriel Hauge, asked me to respond to your letter to him in which you enclosed a copy of "Nominees", published by Morgan Guaranty Trust, and remarked that a similar disclosure by Manufacturers Hanover would be useful.

We have in preparation a report on certain of our Personal Trust & Employee Benefit Trust activities. This will contain a list of nominees and a brief explanation of their use and purpose. A copy of the report will be sent to you as soon as it is available.

Thank you for your suggestion.
Sincerely yours,

WILLIAM MCGORRY,

Senior Vice President.

MELLON BANK N.A.,

Pittsburgh, Pa., August 13, 1974.

Hon. LEE METCALF,

Chairman, Subcommittee on Budgeting, Management and Expenditures Senate Office Building, Washington, D.C.

DEAR SENATOR METCALF: Our Chairman, Mr. James H. Higgins, has referred to me your letter of August 6 requesting information concerning nominee names used by Mellon Bank, N.A.

Nominee names used for personal trust accounts:

1. Pace & Co.-Identifies securities owned in employee benefit accounts. 2. Cost & Co.-Identifies securities owned in charitable accounts.

3. Mac & Co.-Identifies securities owned in agency and trust accounts for individuals.

4. Far & Co.-Identifies foreign securities owned in all types of accounts. Nominee names used for corporate trust accounts:

1. Bert & Co.-Identifies securities owned in various corporate trust accounts. 2. Acly Co.-Identifies securities owned in mutual fund accounts. 3. Lacy & Co.-Identifies securities owned in mutual fund accounts. Yours very truly,

R. E. HUDSON, Jr.,

Vice President.

THE FIRST NATIONAL BANK OF CHICAGO,
August 30, 1974.

Hon. LEE METCALF,
U.S. Senate,

Washington, D.C.

DEAR SENATOR METCALF: Mr. Freeman has asked me to reply to your letter of August 6, 1974. For your information, we list below the nominees used by our Bank for various trust accounts, together with the capacities for which a particular nominee is used:

Olen & Co.-Various trust, investment advisory and custodial accounts.
Final & Co.-Various trust, investment advisory and custodial accounts.
Eagle Co.-Various trust, investment advisory and custodial accounts.
Silo & Co.-Custodian account.

UAM & Co.-Custodian account.
Conac & Co.-Custodian account.
Alfund & Co.-Custodian account.
Investmor & Co.-Custodian account.
Bloom & Co.-Custodian account.
Dearborn & Co.-Custodian account.
Friend & Co.-Custodian account.
Merna & Co.-Custodian account.
Serve & Co.-Custodian account.
Monroe & Co.-Custodian account.
Searsfund & Co.-Custodian account.

Sisco & Co.-Dividend Reinvestment accounts.

We believe that the indentity and address of our nominees, together with the nominees of most other major institutions, is readily available through the American Society of Corporate Secretaries, which periodically publishes a complete list of nominees and addresses.

Very truly yours,

ROBERT D. McEVERS,

Senior Vice President.

CONTINENTAL BANK,

Chicago, Ill., August 16, 1974.

Hon. LEE METCALF,
U.S. Senate,

Washington, D.C.

DEAR SENATOR METCALF: In Mr. Perkins' absence, permit me to respond to your letter requesting a list of our bank's nominees.

I'm sure you've had occasion to examine the publication of the American Society of Corporate Secretaries, Inc., One Rockefeller Plaza, New York, New York 10020, of a list of all nominees which is brought up-to-date on an annual basis. The nominees on the attached list are to be found in that publication.

I'm also taking the liberty of enclosing a news release dated May 2, 1974, in which we too expressed concern about the mystery which seems to surround the use of nominees. I think you will commend the disclosures we have made in this release, getting particularly at the bottom of page 3.

Sincerely,

Enclosures.

RAY F. MYERS, Executive Vice President.

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