A-82015, DECEMBER 23, 1936, 16 COMP. GEN. 613

A-82015: Dec 23, 1936

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RURAL REHABILITATION - LOANS TO MUTUAL AID CORPORATIONS - INTERRELATED PRIVATE AGENCY AND GOVERNMENT PERSONNEL THERE IS NO LEGAL OBJECTION TO A PROPOSED LOAN BY THE RESETTLEMENT ADMINISTRATION TO A MUTUAL AID CORPORATION FOR THE REHABILITATION OF ITS MEMBERS THROUGH THE FURNISHING OF MEDICAL CARE UNDER AUTHORITY CONTAINED IN EXECUTIVE ORDER NO. 7143. NOTWITHSTANDING EMPLOYEES OF SAID ADMINISTRATION ARE ALSO OFFICERS AND DIRECTORS OF THE COOPERATIVE ASSOCIATION. NOT BEING FOR APPLICATION TO THESE EMPLOYEES WHO HAVE NO PECUNIARY OR OTHER INTEREST IN THE PROFITS OR CONTRACTS OF THE ASSOCIATION EXCEPT THE PROTECTION OF THE INTERESTS OF THE UNITED STATES. IT WAS NOTED THAT THE VOUCHER WAS CERTIFIED BY MR.

A-82015, DECEMBER 23, 1936, 16 COMP. GEN. 613

RURAL REHABILITATION - LOANS TO MUTUAL AID CORPORATIONS - INTERRELATED PRIVATE AGENCY AND GOVERNMENT PERSONNEL THERE IS NO LEGAL OBJECTION TO A PROPOSED LOAN BY THE RESETTLEMENT ADMINISTRATION TO A MUTUAL AID CORPORATION FOR THE REHABILITATION OF ITS MEMBERS THROUGH THE FURNISHING OF MEDICAL CARE UNDER AUTHORITY CONTAINED IN EXECUTIVE ORDER NO. 7143, AUGUST 19, 1935, NOTWITHSTANDING EMPLOYEES OF SAID ADMINISTRATION ARE ALSO OFFICERS AND DIRECTORS OF THE COOPERATIVE ASSOCIATION, SECTION 41 OF THE CRIMINAL CODE, 35 STAT. 1097, PROHIBITING INTERRELATED PRIVATE AGENCY AND GOVERNMENT PERSONNEL BUSINESS TRANSACTIONS, NOT BEING FOR APPLICATION TO THESE EMPLOYEES WHO HAVE NO PECUNIARY OR OTHER INTEREST IN THE PROFITS OR CONTRACTS OF THE ASSOCIATION EXCEPT THE PROTECTION OF THE INTERESTS OF THE UNITED STATES.

ACTING COMPTROLLER GENERAL ELLIOTT TO THE ADMINISTRATOR, RESETTLEMENT ADMINISTRATION, DECEMBER 23, 1936:

THERE HAS BEEN RECEIVED YOUR LETTER OF NOVEMBER 30, 1936, AS FOLLOWS:

THERE HAS BEEN CERTIFIED TO THE TREASURY A VOUCHER FOR $50,000 PAYABLE TO THE NORTH DAKOTA (FARMERS) MUTUAL AID CORPORATION, PURSUANT TO A LOAN AGREEMENT UNDER WHICH THE BORROWER AGREES TO USE THE SUM ADVANCED FOR THE FOLLOWING PURPOSE:

"TO FURTHER THE REHABILITATION OF ITS MEMBERS BY FURNISHING TO SUCH MEMBERS AN OPPORTUNITY TO OBTAIN EMERGENCY MEDICAL CARE NECESSARY TO THE PRESERVATION OF LIFE, PROTECTION OF EARNING CAPACITY, AND ALLEVIATION OF SUFFERING IN THE STATE OF NORTH DAKOTA.'

UPON SUCH CERTIFICATION, IT WAS NOTED THAT THE VOUCHER WAS CERTIFIED BY MR. H. R. WOOD, WHO ALSO APPEARED TO HAVE BEEN A DIRECTOR OF THE BORROWER. IN VIEW OF DOUBTS EXPRESSED BY THE COMMISSIONER OF ACCOUNTS AND DEPOSITS AS TO THIS ASPECT OF THE PROPOSED LOAN, AND IN VIEW OF THE FACT THAT SOME QUESTION HAS BEEN RAISED AS TO THE PROPRIETY OF THE PURPOSE FOR WHICH THE LOAN IS TO BE MADE, THE CASE IS HEREBY SUBMITTED FOR APPROVAL BY YOUR OFFICE.

WITH RESPECT TO THE PROPRIETY OF THE LOAN TO A COOPERATIVE ASSOCIATION FOR THE PURPOSE OF FURNISHING MEDICAL SERVICES TO RURAL REHABILITATION CLIENTS, THIS ADMINISTRATION HAD ASSUMED THAT DECISION A-60691 OF MARCH 7, 1935, TO HONORABLE JAMES F. BYRNES CLEARLY AUTHORIZED SUCH LOAN. IN THAT DECISION IT WAS HELD THAT THE TERM "RURAL REHABILITATION AND RELIEF IN STRICKEN AGRICULTURAL AREAS" INCLUDED THE FURNISHING OF "SUBSISTENCE, GOODS, AND SERVICES (FOOD, CLOTHING, SHELTER, MEDICAL SERVICES * * *) TO DESTITUTE FAMILIES IN RURAL AREAS.' UNDER THIS DECISION, AND YOUR DECISION OF MAY 19, 1936 (A-73755) AS TO THE PROPRIETY OF EXPENDING LOAN ALLOCATIONS TO EITHER INDIVIDUALS OR BONA FIDE COOPERATIVES, IT HAD SEEMED CLEAR THAT LOANS FOR THE PURPOSE OF FURNISHING MEDICAL SERVICES TO DESTITUTE FAMILIES IN RURAL AREAS COULD BE MADE EITHER BY LOANS OR GRANTS TO INDIVIDUALS OR, WHERE DEEMED ADMINISTRATIVELY MORE ECONOMICAL AND EFFECTIVE, THROUGH LOANS OR GRANTS TO PROPERLY ORGANIZED AND SUPERVISED COOPERATIVES.

THE PROCEDURE GENERALLY ADOPTED BY THIS ADMINISTRATION TO PROVIDE MEDICAL SERVICES TO DESTITUTE FAMILIES IN RURAL AREAS HAS BEEN THROUGH THE MAKING OF INDIVIDUAL LOANS AND GRANTS TO REHABILITATION CLIENTS. IN MOST REGIONS THIS PROCEDURE HAS OPERATED WITHOUT ANY PARTICULAR DIFFICULTY. HOWEVER, IN THE STATE OF NORTH DAKOTA, THE EXTENT OF DROUGHT IN THE PAST FEW YEARS HAS BEEN SO SERIOUS THAT BOTH THE NEED FOR MEDICAL SERVICES AND THE SIZE OF THE RELIEF ROLLS ARE SUBSTANTIALLY GREATER THAN IN OTHER REGIONS. THE COUNTY SUPERVISORS OF THIS ADMINISTRATION, WHO IN OTHER REGIONS OF THE COUNTRY ARE ABLE TO HANDLE AND SUPERVISE INDIVIDUAL LOANS AND GRANTS FOR MEDICAL SERVICES EFFICIENTLY ARE SO BURDENED IN THE STATE OF NORTH DAKOTA WITH THE SERVICING OF EMERGENCY DROUGHT LOANS AND GRANTS THAT ADEQUATE ATTENTION AND SUPERVISION OVER THE MAKING AND PROPER USE OF LOANS OR GRANTS FOR MEDICAL CARE TO INDIVIDUAL CLIENTS CANNOT BE PROVIDED WITHOUT A SUBSTANTIAL INCREASE IN ADMINISTRATIVE PERSONNEL, BOTH IN CONTACT WITH THE DESTITUTE REHABILITATION AND DROUGHT CLIENTS, AND IN THE PREPARATION OF THE THOUSANDS OF ADDITIONAL INDIVIDUAL LOAN AGREEMENTS, AND LOAN AND GRANT VOUCHERS REQUIRED.

IT WAS TO MEET THIS PECULIAR SITUATION THAT THE NORTH DAKOTA FARMERS MUTUAL AID CORPORATION WAS ORGANIZED TO UNDERTAKE, WITH THE ASSISTANCE OF THIS ADMINISTRATION AND THE COLLABORATION OF STATE OFFICIALS AND STATE MEDICAL AND HOSPITAL ASSOCIATIONS, THE FUNCTION OF COOPERATIVELY CARING FOR THE EMERGENCY MEDICAL NEEDS OF THE MANY THOUSANDS OF DESTITUTE FARM FAMILIES OF NORTH DAKOTA.

THE PLAN WHICH WAS INVOLVED WOULD SEEM TO BE VERY DEFINITELY MORE ECONOMICAL AND EFFICIENT FROM THE STANDPOINT OF BOTH THE UNITED STATES AND THE DESTITUTE FARM FAMILIES INVOLVED THAN THE PROCEDURE OF INDIVIDUAL LOANS AND GRANTS. THE NORTH DAKOTA STATE BOARD OF PUBLIC WELFARE, NORMALLY CHARGED WITH THE RESPONSIBILITY OF PROVIDING MEDICAL CARE FOR THOSE UNABLE TO MEET THE COST THEREOF, BUT UNABLE BECAUSE OF LACK OF FUNDS TO MEET THE ACUTE SITUATION WHICH NOW EXISTS, WILL MAKE AVAILABLE TO THE COOPERATIVE ASSOCIATION THE NECESSARY ADMINISTRATIVE PERSONNEL. ADDITION, STATE-WIDE ASSOCIATIONS REPRESENTING PHYSICIANS, DENTISTS, AND HOSPITALS HAVE ARRANGED WITH THE COOPERATIVE ASSOCIATION FOR A SCHEDULE OF FEES, WHICH WILL BE FROM FORTY TO FIFTY PERCENT (40-50 PERCENT) LESS THAN THOSE GENERALLY CHARGED IN NORTH DAKOTA AND WHICH WOULD HAVE TO BE PAID BY THE DESTITUTE FAMILIES IF FUNDS WERE MADE AVAILABLE BY INDIVIDUAL LOANS AND GRANTS.

IN ACCORDANCE WITH THE PROVISIONS OF EXECUTIVE ORDER 7143, MEMBERSHIP IN THE COOPERATIVE WILL, UNDER ITS CHARTER AND BYLAWS, BE AVAILABLE TO CLIENTS OF THE RESETTLEMENT ADMINISTRATION AND WILL NOT BE AVAILABLE TO ANY PERSONS WHO ARE NOT MEMBERS OF DESTITUTE OR LOW INCOME FAMILIES IN RURAL AREAS. THE MEDICAL CARE, WHICH THE ASSOCIATION IS AUTHORIZED TO OBTAIN FOR ITS MEMBERS, IS RESTRICTED BY ITS CORPORATE BYLAWS TO TREATMENT OF ACUTE ILLNESSES OR ACUTE RECURRENCE OF CHRONIC CONDITIONS, OF SUCH NATURE AS TO CAUSE ACUTE SUFFERING, INTERFERE WITH EARNING CAPACITY, ENDANGER LIFE, OR THREATEN A PERMANENT PHYSICAL HANDICAP PREVENTABLE BY IMMEDIATE MEDICAL CARE. FURTHERMORE, EVEN THESE LIMITED TYPES OF EMERGENCY MEDICAL SERVICES WILL BE AVAILABLE ONLY UPON OBTAINING A WRITTEN REQUISITION, APPROVED BY A DULY AUTHORIZED AGENT OF THE ASSOCIATION. THE PHYSICIAN RENDERING MEDICAL CARE ON THE BASIS OF SUCH REQUISITIONS WILL BE PAID BY THE COOPERATIVE ASSOCIATION, ON THE BASIS OF THE EMERGENCY RATES INDICATED ABOVE, AFTER CAREFUL VERIFICATION OF THE REASONABLENESS OF THE CHARGES. IT IS AT PRESENT CONTEMPLATED THAT THE COOPERATIVE ASSOCIATION WILL OBTAIN A NOTE FROM EACH MEMBER RECEIVING THE EMERGENCY MEDICAL SERVICES COVERING THE AMOUNT PAID BY THE ASSOCIATION, WITH THE EXPECTATION THAT, IN AT LEAST A SUBSTANTIAL NUMBER OF CASES, ULTIMATE REPAYMENT CAN BE OBTAINED. FOR THIS REASON, THE PROPOSED INITIAL ADVANCE TO THE COOPERATIVE IS IN THE NATURE OF A LOAN, RATHER THAN A GRANT.

IN VIEW OF THE FOREGOING FACTS, IT HAS SEEMED TO THIS ADMINISTRATION THAT THE REQUIRED EMERGENCY MEDICAL CARE FOR THE DESTITUTE FARM FAMILIES INVOLVED CAN BE MORE EFFICIENTLY AND ECONOMICALLY PROVIDED BY THIS COOPERATIVE ASSOCIATION, OPERATING AND FINANCED IN THE MANNER INDICATED ABOVE, THAN THROUGH INDIVIDUAL LOANS OR GRANTS, AND IT HAD NOT OCCURRED TO US THAT THERE WAS ANY LEGAL OBJECTION TO THE PROPOSAL. HOWEVER, IN VIEW OF THE APPARENT DOUBTS WHICH HAVE BEEN RAISED, YOUR DECISION IS RESPECTFULLY REQUESTED AS TO WHETHER YOUR OFFICE WOULD BE REQUIRED TO OBJECT TO THIS LOAN OR TO SUCH SUPPLEMENTARY LOANS OR GRANTS AS MAY HEREAFTER BE REQUIRED.

THE SECOND QUESTION ON WHICH YOUR DECISION IS REQUESTED IS THE PROPRIETY OF HAVING EMPLOYEES OF THE RESETTLEMENT ADMINISTRATION ACT AS OFFICERS OR DIRECTORS OF THE NORTH DAKOTA FARMERS MUTUAL AID CORPORATION, IN VIEW OF THE PROVISIONS OF SECTION 93 OF TITLE 18 OF THE UNITED STATES CODE.

FOUR EMPLOYEES OF THE RESETTLEMENT ADMINISTRATION, NAMELY, H. R. WOOD,R. C. WILLIAMS, P. M. REYNOLDS, AND J. F. VANDENOVER, HAVE BEEN ELECTED BY THE MEMBERS AS OFFICERS AND/OR DIRECTORS OF THE ASSOCIATION. THESE PERSONS HAVE NO PECUNIARY OR OTHER INTERESTS IN THE PROFITS OR CONTRACTS OF THE ASSOCIATION OTHER THAN THEIR INTERESTS AS EMPLOYEES OF THE RESETTLEMENT ADMINISTRATION IN PROTECTING THE INTERESTS OF THE UNITED STATES AS CREDITOR AND IN ASSURING THAT THE ASSOCIATION IS SO CONDUCTED AS TO CONTRIBUTE TO THE RELIEF OF DESTITUTE AND LOW-INCOME FAMILIES IN NORTH DAKOTA. THE ONLY POSSIBLE PROFITS WHICH COULD ACCRUE TO MEMBERS OF THE ASSOCIATION ARE THE SAVINGS EFFECTED THROUGH THE LOWER CHARGES MADE AVAILABLE TO MEMBERS OF THE ASSOCIATION. AS TO THESE CHARGES, THE ARTICLES OF INCORPORATION AND THE BYLAWS EXPRESSLY PROVIDE THAT NONE OF THE ORIGINAL INCORPORATORS, IN WHICH GROUP THE ABOVE NAMED EMPLOYEES FALL, SHALL RECEIVE ANY OF THE MEDICAL CARE BENEFITS AFFORDED BY THE ASSOCIATION. THESE EMPLOYEES WILL NOT RECEIVE ANY COMPENSATION FROM THE ASSOCIATION AS DIRECTORS OR OFFICERS. THEIR FUNCTIONS WILL BE MERELY TO PROTECT THE INTERESTS OF THE UNITED STATES AS CREDITOR OF THE ASSOCIATION AND TO ASSURE THAT THE COOPERATIVE IS SO CONDUCTED UNDER THE SUPERVISION OF THE RESETTLEMENT ADMINISTRATION AS TO PROTECT ADEQUATELY THE INTERESTS OF THE REHABILITATION CLIENTS WHO WILL BE MEMBERS THEREOF.

IT WOULD SEEM, THEREFORE, THAT THE PROVISIONS OF SECTION 93 OF TITLE 18 OF THE UNITED STATES CODE ARE NOT APPLICABLE, SINCE THE EMPLOYEES IN QUESTION ARE SERVING FOR THE SOLE PURPOSE OF PROTECTING THE GOVERNMENT'S INTEREST AND ASSURING THE PROPER CONDUCT OF THE AFFAIRS OF THE COOPERATIVE IN ACCORDANCE WITH THE PROVISIONS OF SECTION 2 OF EXECUTIVE ORDER 7143, WITH NO POSSIBILITY OF ANY PECUNIARY GAINS TO THEMSELVES BY VIRTUE OF THEIR STATUS AS SUCH OFFICERS OR DIRECTORS. THAT THE STATUTE IS NOT APPLICABLE IN A CASE SUCH AS THIS SEEMS TO BE INDICATED BY DECISION OF THE UNITED STATES SUPREME COURT IN UNITED STATES V. CHEMICAL FOUNDATION, INC., 272 U.S. 1 (1925). IF YOUR OFFICE IS OF THE OPINION THAT, NOTWITHSTANDING THE FOREGOING EXPLANATION, THE APPOINTMENT OF THESE EMPLOYEES AS OFFICERS AND DIRECTORS OF THE COOPERATIVE ASSOCIATION IS IMPROPER, IMMEDIATE STEPS, OF COURSE, WILL BE TAKEN TO REQUIRE THE COOPERATIVE TO ELECT OTHER DIRECTORS AND OFFICERS WHO ARE IN NO WAY CONNECTED WITH THIS ADMINISTRATION.

AS INDICATED ABOVE, THE NEED FOR PROVIDING EMERGENCY MEDICAL CARE IN NORTH DAKOTA IS MOST ACUTE. FOR THIS REASON, YOUR EARLY DECISION IN THE MATTER IS RESPECTFULLY REQUESTED.

THIS OFFICE HAS SUGGESTED TO THE COMMISSIONER OF ACCOUNTS AND DEPOSITS OF THE UNITED STATES TREASURY THAT THE VOUCHER IN QUESTION BE TRANSMITTED TO YOU FOR PREAUDIT AT THIS TIME SO THAT IT CAN BE CONSIDERED TOGETHER WITH THE FOREGOING LETTER.

SECTION 93 OF TITLE 18 OF THE U.S.C. (SEC. 41 OF THE CRIMINAL CODE, 35 STAT. 1097) PROVIDES:

NO OFFICER OR AGENT OF ANY CORPORATION, JOINT STOCK COMPANY, OR ASSOCIATION, AND NO MEMBER OR AGENT OF ANY FIRM, OR PERSON DIRECTLY OR INDIRECTLY INTERESTED IN THE PECUNIARY PROFITS OR CONTRACTS OF SUCH CORPORATION, JOINT STOCK COMPANY, ASSOCIATION, OR FIRM, SHALL BE EMPLOYED OR SHALL ACT AS AN OFFICER OR AGENT OF THE UNITED STATES FOR THE TRANSACTION OF BUSINESS WITH SUCH CORPORATION, JOINT STOCK COMPANY, ASSOCIATION, OR FIRM. WHOEVER SHALL VIOLATE THE PROVISION OF THIS SECTION SHALL BE FINED NOT MORE THAN TWO THOUSAND DOLLARS AND IMPRISONED NOT MORE THAN TWO YEARS.

IN UNITED STATES V. CHEMICAL FOUNDATION, INC., 272 U.S. 1, THE SUPREME COURT OF THE UNITED STATES HELD THAT THIS STATUTORY PROHIBITION DID NOT APPLY TO A TRANSFER BY THE ALIEN PROPERTY CUSTODIAN OF CERTAIN SEIZED CHEMICAL PATENTS TO AN INCORPORATED "CHEMICAL FOUNDATION" WHICH THE ALIEN PROPERTY CUSTODIAN AND OTHER OFFICERS AND AGENTS OF THE GOVERNMENT WERE INSTRUMENTAL IN ESTABLISHING AND OF WHICH THE ALIEN PROPERTY CUSTODIAN WAS PRESIDENT, THE CORPORATE SHARES HAVING ALL BEEN SUBSCRIBED AND PAID FOR BY OTHERS INTERESTED IN THE CHEMICAL INDUSTRIES. THE COURT SAID (PP. 18 AND 19) RESPECTING THE APPLICATION OF THE STATUTE IN QUESTION TO THE TRANSACTION:

SECTION 41 WAS ENACTED WHEN THERE WAS NO WAR, AND LONG BEFORE THE TRADING WITH THE ENEMY ACT. IT LAYS DOWN A GENERAL RULE FOR THE PROTECTION OF THE UNITED STATES IN TRANSACTIONS BETWEEN IT AND CORPORATIONS AND TO PREVENT ITS ACTION FROM BEING INFLUENCED BY ANYONE INTERESTED ADVERSELY TO IT. IT IS A PENAL STATUTE AND IS NOT TO BE EXTENDED TO CASES NOT CLEARLY WITHIN ITS TERMS OR TO THOSE EXCEPTIONAL TO ITS SPIRIT AND PURPOSE. * * * NEITHER MR. CARVAN NOR ANY OF THE OTHERS WHO ACTED FOR THE UNITED STATES HAD ANY FINANCIAL INTEREST IN THE FOUNDATION, ITS PROFITS, OR ITS CONTRACTS. * * * THE ARRANGEMENT WAS INTENDED TO AMOUNT TO A PUBLIC TRUST FOR THOSE WHOM THE PATENTS WILL BENEFIT AND FOR THE PROMOTION OF AMERICAN INDUSTRIES, AND TO GIVE THEM THE RIGHT TO HAVE ON EQUAL AND REASONABLE TERMS LICENSES TO MAKE, USE, AND SELL THE INVENTIONS COVERED BY THE PATENTS. THE FOUNDATION IS PROPERLY TO BE CONSIDERED AN INSTRUMENTALITY CREATED UNDER THE DIRECTION OF THE PRESIDENT TO EFFECT THAT DISPOSITION AND SUBSEQUENT CONTROL OF THE PATENTS WHICH HE DETERMINED TO BE IN THE PUBLIC INTEREST. THE TRANSACTIONS COMPLAINED OF DID NOT INVOLVE ANY OF THE EVILS AIMED AT BY SEC. 41. THE ACT WILL BE CONSTRUED AND APPLIED AS NOT QUALIFIED OR AFFECTED BY THAT PROVISION OF THE CRIMINAL CODE. * * *

IN VIEW OF THESE PRINCIPLES STATED BY THE SUPREME COURT RESPECTING THE APPLICATION OF THE STATUTE AND YOUR STATEMENT THAT THE EMPLOYEES OF THE RESETTLEMENT ADMINISTRATION ACTING AS DIRECTORS OR OFFICERS OF THE COOPERATIVE ASSOCIATION HAVE NO PECUNIARY OR OTHER INTERESTS IN THE PROFITS OR CONTRACTS OF THE ASSOCIATION EXCEPT TO PROTECT THE INTERESTS OF THE UNITED STATES AS CREDITOR OF THE ASSOCIATION AND TO ASSURE THAT THE COOPERATIVE IS SO CONDUCTED UNDER THE SUPERVISION OF THE RESETTLEMENT ADMINISTRATION AS TO PROTECT ADEQUATELY THE INTERESTS OF THE REHABILITATION CLIENTS WHO WILL BE MEMBERS THEREOF, WHICH ARRANGEMENT APPEARS IN CONSONANCE WITH THE PROVISIONS OF EXECUTIVE ORDER NO. 7143, AUGUST 19, 1935, AUTHORIZING LOANS BY THE RESETTLEMENT ADMINISTRATION TO BONA FIDE AGENCIES OR COOPERATIVE ASSOCIATIONS "FOR SUCH OTHER PURPOSES AS MAY BE NECESSARY IN THE ADMINISTRATION OF APPROVED PROJECTS INVOLVING RURAL REHABILITATION OR RELIEF IN STRICKEN AGRICULTURAL AREAS" ON THE CONDITION, INTER ALIA, THAT SUCH AGENCIES OR ASSOCIATION ,BE SO CONDUCTED UNDER THE SUPERVISION OF THE RESETTLEMENT ADMINISTRATION AS TO PROTECT ADEQUATELY THE INTERESTS OF THE MEMBERS OR PARTICIPANTS THEREIN," AND AS THE LOAN AGREEMENT APPEARS TO COMPLY OTHERWISE WITH THE CONDITIONS, AND RESTRICTIONS OF THE SAID EXECUTIVE ORDER NO. 7143, YOU ARE ADVISED THAT THIS OFFICE WILL NOT BE REQUIRED TO OBJECT TO THE EXPENDITURE OF FUNDS FOR THE PROPOSED LOAN.

THE LOAN VOUCHER WILL BE PREAUDITED ACCORDINGLY AND RETURNED TO THE COMMISSIONER OF ACCOUNTS AND DEPOSITS IN DUE COURSE.