BRITISH MINISTRY OP SHIPPING,
Bowling Green 9 - 5310,
25 Broadway,
NSW YORK.
REPRESENTATIVE IN THE U.S.A.
December 28th, 1939.
O.K. Eakins, Esq., of the Secretariat,
Ministry of Shipping,
Berkeley Square House,
LONDON, W.I.
Dear Mr. Eakins:
We confirm exchange of cables (your No. 32 received on the
22nd instant, and our reply, No. 82, of the 23rd) as per copies
herewi th.
On receipt of your cable, we conferred with the Embassy to get
their views;    we also discussed the matter with Mr. George de Forest
Lord (our Admiralty counsel) and Mr. Cletus Keating (another
prominent Admiralty lawyer), both of whom have been very active in
matters connected with the Neutrality Act, particularly in
connection with trying to ease the burdens that this Act has placed
on British vessels trading in the so-called cold belligerent zones,
where of course these lines are still meeting competition of
American-flag vessels.
It is our opinion - in which the Embassy fully concur - that it
would be very inadvisable for any British interests to foster any
amendment to the Neutrality Act at this time.     There is still some
weight of opinion in this country against what has already been
done in removing the embargo on shipments of war materials to
belligerent countries, and we feel that any attempt at this time by
British interests to still further broaden the provisions of the
Act might well react against us and very likely have the effect of
interfering with the broader aspects of the situation and possibly
result in certain restrictions being placed on the export of certain
war materials.
The American exporters have found certain provisions of the
Act, in connection with the transfer of title, rather onerous and
quite a few of the American trade associations have in mind trying
to have these provisions liberalized when Congress reassembles in
January.     They have in mind endeavoring to amend the Act so that
the present title transfer provisions would be deleted and that
exports should be treated, in so far as title is concerned, along
the same lines as already provided for insurance in Section 2-(d;
of the Act.     This of course would not affect any of the credit
provisions of the Act but if it was done, it would do away v/ith all
the troubles that have arisen in connection with obtaining and
filing with the Customs authorities the necessary oaths covering
the transfer of title.
In your cable you refer to the original proposed amendment to
the Act, which was merely a deletion of the word "American" in
Section 2-(g), which would have made this Section read in part as
follows:    "The provisions of subsections (a) and (c) of this section
shall not apply to transportation by vessels (other than aircraft)
of mail, passengers, or any articles or materials.....".     Had this
amendment been adopted it would, of course, have put vessels of all
flags on an equal footing, in regard to the title question, in all
trades other than those in the combat and restricted areas.
NEUTRALITY ACT
/In
In our ©pinioni it is most unlikely that Congress would be
willing to again consider this particular amendment as there is
a very decided feeling that as American vessels have "been prohibited
from trading in the combat and restricted areas, these vessels
should receive special consideration in the other zones.     If any
amendment can "be secured, it is our opinion that it is much more
likely to be along the lines indicated earlier in this letter in
connection frith the insurance feature.
Yours faithfully,
(signed) E.P. Rees.
Director.
EM I AM
Knclosures
(In Duplicate)