business (paragraph 79), while paragraph 75 lists certain items peculiar to travel abroad (passports, visas, photographs, birth certificates, inoculations), but the regulations do not specify or imply an item for the cost of travelers' checks. In such circumstances, and noting that the statute with respect to the Export-Import Bank permits reimbursement of travel expenses only in accordance with the Standardized Government Travel Regulations, the allowance of any items not authorized therein-however necessary in fact-would amount to a waiver of the statute or an amendment of the regulations, neither of which has this office been empowered to make. Rather, the indicated remedy, in the view that travelers' checks are necessary, is to propose an amendment to the regulations. As now constituted, the regulations do not provide for an expense of that nature, and your first question is answered accordingly. As to the repurchase of travelers' checks with any foreign currency unexpended at the end of the trip (aside from the reasons just stated) it is not clear why any such expense need be incurred at the time of departure for the return trip over and above the cost of an ordinary commercial draft on a bank in this country. Limiting your second question to the situation evidently in contemplation, your inquiry appears to be whether there may be reimbursed the loss incurred by a traveler abroad who, having procured more local funds than were used for his stay in a particular country, reconverts the unused balance to dollars and pays a commission on the latter transaction in the form of a slightly higher exchange rate than that for which the dollars first were sold. The difference between the buying and selling rates normally is very small-one or two percent and frequently even less-and arises from the bankers' deductions and charges for the sale of a dollar draft on New York. See 19 Comp. Gen. 652; id. 993. It formerly was held that the expense of reconversion of excess. purchases of local funds is personal to the traveler and not reimbursable. A-6449, December 4, 1924; A-10005, August 5, 1925. Subsequently there was incorporated into the Standardized Government Travel Regulations, 1934 edition, under paragraph 8 (c), “Foreign currency.-Commissions for conversion of currency in foreign countries may be allowed. be allowed. (See pars. 90, 91.)" Perhaps due to the comparatively minute sums involved, no reconsideration of the earlier decisions has been requested, but, so far as such reconversions reasonably are related to the necessities of public travel, their expense is reimbursable under that paragraph. Such relation would be established if the amount originally converted into the local currency bore some reasonable relation to the estimated official needs of the traveler in that country, that is, the anticipated per diem, transportation, and 598796-44-vol. 23- -16 miscellaneous actual expenses. In claiming any such item it would be necessary for the traveler to show, by appropriate bank tickets or other evidence, the rates and amounts of both the original conversion and the reconversion, as well as the prevailing buying rate on the day of reconversion, since it is the difference between that buying rate and the selling rate at which dollars were repurchased that is reimbursable, not any variation in the basic value of the dollar during the period the local money is held by the traveler. Any gain or loss in the latter connection is for the traveler's account alone. Finally, contrary to the suggestion contained in the memorandum submitted, neither question is affected or controlled by the act of March 26, 1934, 48 Stat. 466, which provides a program for reimbursement of currency losses of an entirely different nature, namely, those losses incurred by officers of the Government in the service abroad due to the appreciation of foreign currency exchange rates over the prevailing rates of exchange in effect at the time the American dollar was devalued. See Executive Order 7972, as amended. The voucher forwarded with the bank's letter is returned herewith. Since it represents a reclaim of items suspended in a prior payment, the present voucher should be forwarded to the Claims Division of this office for direct settlement as a claim. If the account containing the original voucher has not been forwarded to this office by such time, the original voucher may be withdrawn from such account and forwarded for advance consideration with the present claim. Referring to the items listed on the claim, the cost of the travelers' checks will be for elimination in view of the foregoing. The items for commission on exchange of travelers' checks on January 10, 21, 22, 25, 27, and 28 will be expected to be established by exchange receipts attached to the original voucher. See paragraphs 80 (d) and 90 of the travel regulations. The five items totaling $1.26, comprising the commission on exchange at Quito, Ecuador, appear to merit a somewhat more clarifying statement than that submitted, in order that it may be made plainly to appear in what way the amounts claimed are in fact the cost of converting dollar checks into local funds, or vice versa. (B-36497) RENTAL, SUBSISTENCE AND QUARTERS ALLOWANCES; FAMILY ALLOWANCE BENEFITS; TRANSPORTATION FOR DEPENDENTS— MEMBERS OF WOMEN'S ARMY CORPS Under the provisions of sections 2 and 3 of the act of July 1, 1943, making applicable to officers and enlisted members of the Women's Army Corps and their dependents and beneficiaries the rights, benefits, and privileges applicable "in like cases" to officers appointed under the act of September 22, 1941, or the laws and regulations applicable in like cases" to enlisted men, as the case may be, such members are entitled to payment of increased allowances on account of dependents, not in all cases in which male members in the service would be entitled to said allowances, but in cases where, as regards dependents, the situation of the woman is "like" or analogous to that of a man in service. The husband of a member of the Women's Army Corps may not be regarded in any case as a dependent of such member for the purpose of payment to her of the increased rental and subsistence allowances authorized to be paid officers, or the quarters allowance authorized for enlisted men of the first three pay grades, by the Pay Readjustment Act of 1942 on account of "dependents" as defined in section 4 of the said act. A member of the Women's Army Corps may not be paid increased rental and subsistence allowances or quarters allowance, authorized by the Pay Readjustment Act of 1942, on account of her unmarried child under 21 years of age except in cases where the child's father is deceased and the mother is not remarried, or under circumstances of a particular case establishing that the child is in fact dependent upon his mother. Members of the Women's Army Corps, otherwise entitled to increased rental and subsistence allowances or quarters allowance authorized by the Pay Readjustment Act of 1942 on account of "dependents" as defined in section 4 of the said act, may be paid such increased allowances on account of a father or mother where it is established that the father or mother is in fact dependent on such member for his or her chief support. A member of the Women's Army Corps, otherwise entitled to the transportation for dependents authorized by section 12 of the Pay Readjustment Act of 1942 and section 4 of the act of June 5, 1942, is entitled to transportation for her father or mother in fact dependent on her for chief support, and for her unmarried child under 21 years of age, if the father of said child is deceased and the member is not remarried, or if the child is in fact dependent on her for his support. The husband of an enlisted member of the Women's Army Corps may not be regarded as a "dependent" within the meaning of the Servicemen's Dependents Allowance Act of 1942 so as to entitle him to payment of the family allowance benefits authorized by the said act for dependents of enlisted personnel of designated grades. The family allowance benefits authorized by the Servicemen's Dependents Allowance Act of 1942 for dependents of enlisted men of designated grades may be paid to a child of a member of the Women's Army Corps if the child's father is deceased and the mother is not remarried, or, in case the father is not deceased, if the child is in fact dependent upon his mother. The family allowance benefits authorized by the Servicemen's Dependents Allowance Act of 1942 for dependents of enlisted men of designated grades may be paid to class B dependents (parent, grandparent, brother or sister) of enlisted personnel of the Women's Army Corps, even though she is receiving the said allowance as a wife of an enlisted man, upon showing, as provided in the act, that the relative is dependent on such enlisted member for "a substantial portion of his support." The six months' death gratuity benefits payable under the act of December 17, 1919, as amended, to the widow, child, or other previously designated dependent relative of a deceased officer or enlisted man of the Army may be paid to the surviving husband of a deceased member of the Women's Army Corps to the exclusion of a child or a designated relative. A member of the Women's Army Corps is not entitled to transportation at Government expense for her husband, whether or not he is dependent in fact upon her, under section 4 of the act of June 5, 1942, and section 12 of the Pay Readjustment Act of 1942, authorizing such transportation for dependents, as defined in section 4 of the latter act, of officers and enlisted men of designated grades. Where the husband of a member of the Women's Army Corps is a member of the armed forces and drawing increased rental and subsistence allowances or quarters allowance authorized under the Pay Readjustment Act of 1942 on account of dependents, their child or children may not be regarded as dependent upon the mother so as to entitle her to increased allowances (rental and subsistence, quarters, or transportation for dependents) on account of dependents. A divorced member of the Women's Army Corps is not entitled on account of her child to payment of the increased rental and subsistence allowances or quarters allowance on account of dependents, authorized under the Pay Readjustment Act of 1942, in the absence of an affirmative showing that the responsibility of the child's support has been shifted to the mother. An officer or enlisted man is not entitled to increased rental and subsistence allowances or quarters allowance under the Pay Readjustment Act of 1942 on account of a wife who is a member of the Women's Army Corps. An officer, or enlisted man of the first three pay grades, whose wife is a member of the Woman's Army Corps and who has a dependent child as defined in section 4 of the Pay Readjustment Act of 1942 may be paid increased rental and subsistence allowances or quarters allowance under said act on account of dependents. Where the husband of an enlisted member of the Women's Army Corps is an officer or enlisted man in the armed services and is receiving increased allowances on account of their dependent child, the family allowance benefits authorized by the Servicemen's Dependents Allowance Act of 1942 to be paid to dependents of enlisted personnel of designated grades are not payable to the child as a dependent of the Women's Army Corps member. A waiver by a member of the Women's Army Corps or by her husband, who is a member of the armed services, of the statutory right to allowances (rental, quarters, or transportation for dependents) will not be recognized by this office as having any effect upon the benefits authorized by the statutes for the spouse in whose favor the waiver is attempted. Assistant Comptroller General Yates to the Secretary of War, September 24, 1943: There has been considered your letter of August 16, 1943, in which you presented for decision several questions relative to dependency allowances, etc., for members of the Women's Army Corps established by the act of July 1, 1943, 57 Stat. 371, Public Law 110. Section 2 of the said act, relating to enlisted personnel of that corps, provides: All laws and regulations now or hereafter applicable to enlisted men or former enlisted men of the Army of the United States and their dependents and beneficiaries shall, in like cases and except where otherwise expressly provided, be applicable respectively to enlisted personnel and former enlisted personnel of such corps and their dependents and beneficiaries.. Section 3 thereof, relating to commissioned officers, provides: * They and their dependents and beneficiaries shall have all of the rights, privileges, and benefits accorded in like cases to other persons under that Act, [September 22, 1941, 55 Stat. 728] except where otherwise expressly provided. The questions stated in your letter will be considered in their order. (1) May payments of increased allowances for rental and subsistence on account of dependents be made to officers of the WAC under the Pay Readjustment Act of 1942, as amended? (2) May payments of monetary allowance for quarters on account of dependents be made to enlisted personnel of appropriate grades of the WAC under the Pay Readjustment Act of 1942, as amended? Sections 5 and 6 of the Pay Readjustment Act of June 16, 1942, 56 Stat. 361, provide: Sec. 5. Each commissioned officer on the active list, or on active duty, below the grade of brigadier general or its equivalent, in any of the services mentioned in the title of this Act, shall be entitled at all times, in addition to his pay, to a money allowance for subsistence. allowance is hereby fixed at 70 cents per day. The value of one subsistence said services receiving the base pay of the first, second, third, or sixth period the amount of this allowance shall be equal to two subsistence allowances, and to each officer receiving the base pay of the fourth or fifth period the amount of this allowance shall be equal to three subsistence allowances: Provided, That an officer with no dependents shall receive one subsistence allowance in lieu of the above allowances. Sec. 6. Except as otherwise provided in this section, each commissioned officer below the grade of brigadier general or its equivalent, in any of the services mentioned in the title of this Act, while either on active duty or entitled to active-duty pay shall be entitled at all times to a money allowance for rental of quarters. To an officer having a dependent, receiving the base pay of the first period the amount of said allowance shall be $60 per month, to such an officer receiving the base pay of the second period the amount of this allowance shall be $75 per month, to such an officer receiving the base pay of the third period the amount of this allowance shall be $90 per month, to such an officer receiving the base pay of the fourth period the amount of this allowance shall be $105 per month, and to such an officer receiving the base pay of the fifth or sixth period the amount of this allowance shall be $120 per month. To an officer having no dependents, receiving the base pay of the first period the amount of said allowance shall be $45 per month, to such an officer receiving the base pay of the second period, the amount of said allowance shall be $60 per month, to such an officer receiving the base pay of the third period the amount of said allowance shall be $75 per month, to such an officer receiving the base pay of the fourth period the amount of said allowance shall be $90 per month, and to such an officer receiving the base pay of the fifth or sixth period the amount of said allowance shall be $105 per month. Section 10 of the said Pay Readjustment Act of 1942, 56 Stat. 363, 364, authorizes a money allowance for quarters for certain enlisted men, as follows: Each enlisted man of the first, second, or third grade, in the active military, naval, or Coast Guard service of the United States having a dependent as defined in section 4 of this Act, shall, under such regulations as the President may prescribe, be entitled to receive, for any period during which public quarters are not provided and available for his dependent, the monthly allowance for quarters authorized by law to be granted to each enlisted man not furnished quarters in kind: Provided, That such enlisted men shall continue to be entitled to this allowance although receiving the allowance provided in the first paragraph of this section if by reason of orders of competent authority his dependent is prevented from dwelling with him. Section 4 of that act defines the term "dependent" as including "at all times and in all places a lawful wife and unmarried children under twenty-one years of age," and, also, the father or mother of the person concerned "provided he or she is in fact dependent on such person for his or her chief support." The applicability of such sections to women in the armed services has been the subject of several recent decisions of this office. In decision dated October 29, 1942, 22 Comp. Gen. 406, it was held that a nurse in the Nurse Corps (female) of the Navy was not entitled to increased rental and subsistence allowances on account of dependents. Also, it was held that such increased allowances on account of dependents were not authorized for members of the Women's Reserve in the Coast Guard Reserve and the Women's Reserve in the Naval Reserve. 22 Comp. Gen. 838, id. 955; B-32874, August 4, 1943. Speaking generally, the basis of those decisions was that the statutory provisions authorizing payment of increased allow |