-91-


 The Code Authority officials spent much time and study on this
phase of activities, without an approved final result being obtained
and it cannot be said that this matter was the cause of controversy
for all hoped and looked for such a system. It was, however, found
extremely difficult to work this out satisfactorily, and only.toward
the end of the code period was a definite recommendation made.

 On pp. 225 paragraph 4, Exhibit G the Code Director remarks
"11the average ladies handbag contains about twenty different materials
and requires about thirty man operations to complete. A general
lack of knowledge of computing costs by the manufacturers in the
industry has resulted in ruinous competition" which explains the
difficulty in working out anything approaching a workable system.

 Exhibit P was forwarded to the Administrator for approval
December 26, 1934 and February 18, 1935 Orton W. Boyd of Planning
and Research filed a memorandum, made part of this exhibit. It will
be seen that as set up, the formula was in some respects contrary
to Office memorandum 228-3 and in others not considered good
accounting practice. Many conferences between Mr. Boyd and the Code
Directors were held but like so much other good work this was never
carried to a final conclusion.

 1. Price Filing

 There was not any provision made for filing prices but an attempt
was made to set price groupings (See Exhibit Z.) At meeting No. 8
held August 2, 1934 it was decided that the subject matter of Exhibit Z
be taken up with retailers interested. Since minutes in our files
disclose nothing further on this matter it is to be presumed it lapsed.

 a. Waiting Periods.

 Not provided for.

 2. Emergency Price.Bases,

 Not provided for.

 3. Accounting Systems or Cost Systems

 Submitted but never aniroved (See Section F this chapter).

 4. Administrative Price Policy

 Admitted to be desirable and necessary but since system
submitted never reached final approval did not become operative.

 5. Classification of Customers

 No code provision

 6. Price Differentials


No provision.