Skip navigation
Ensuring a Safe and Sound Federal Banking System for All Americans Site Map | Text Size: S M L


Resources for bankers

Interpretations and Actions: May 1996

Vol. 9, No. 5

Clickable document numbers indicate HTML versions are available. WordPerfect for Windows versions of documents are available for download by clicking on the WP that follows the letter description.

PLEASE NOTE: Interpretive Letters and No Objection Letters reflect the views of the Comptroller's legal staff. Corporate Decisions and Decisions (CRA) are from the office of Bank Organization and Structure. The list of CRA Ratings is from the Communications Division.

Copies of documents not available electronically should be requested by e-mail or by postal mail from the Office of the Comptroller of the Currency, Attn: Communications, Washington, D.C. 20219.

Please cite the letter number when reporting or summarizing documents from this package. This helps to process single requests in a more timely manner.

Interpretive Letters

Letter No. Topic
719 Letter concludes that an ESOP is a "company' for purposes of 12 U.S.C. 371c and that an ESOP that controls at least 25% of a bank's voting stock is an "affiliate" under sec. 371c (supersedes existing OCC interpretive letter #261). (10/26/89)
720 Group of affiliate national banks may collectively own, through operating subsidiaries, minority interest in a merchant credit card processing subsidiary. (01/26/96)
721 Letter discusses the use of an affiliated bank to originate and close consumer loans. (03/06/96)
722 A national bank may invest CIF assets in mutual funds, including mutual funds that pay the bank a servicing fee, without the bank having to reduce its trustee fees, if the bank concludes, based upon a reasoned opinion of trust counsel, that such an arrangement is authorized by applicable state law, is consistent with the trust instrument, is appropriate for the particular trust accounts, and is consistent with OCC regulations, including in particular 12 C.F.R. 9.18(b)(12). (03/12/96)
723 Letter discusses the application of CRA to a bank's purchases of debentures issued by a specialized small business investment company. (04/15/96)
724 Bank can sell vehicle service contracts to customers who use home equity loan proceeds to purchase a vehicle, and the maturity of the service contract may be different from the maturity of the loan. (04/22/96)
725 National bank to establish an operating subsidiary to engage in permissible derivatives-related activities. (05/10/96)

Corporate Decisions

Letter No. Topic
96-20 Application to merge Fleet Bank of New York, National Association, Schenectady, New York, with and into NatWest Bank National Association, Jersey City, New Jersey, under the charter of the latter and with the title, Fleet Bank, National Association; (Control Number 96ML020004), (04/12/96).
96-21 Application of Franklin National Bank of Virginia, Alexandria, Virginia, to establish a branch in Bethesda, Maryland; (Control Number 96SE05028), (04/15/96).
96-22 Applications of Community National Bank, South Boston, Virginia, to establish a branch in Henderson, North Carolina, and to establish a branch in Louisburg, North Carolina; (Control Numbers 96SE050027 & 96SE050028), (04/19/96).

Approvals with Conditions Enforceable under 12 U.S.C. 1818

Letter No. Topic
200 NatWest Bank National Association, Jersey City, NJ, notification to acquire three subsidiaries from its holding company and to establish a fourth subsidiary to take over certain additional activities now conducted in an affiliate. (Control Numbers 96ML08004 through 007), 04/12/96
201 First Financial Services Group, National Association, Zanesville, OH, application for a new bank charter limited to fiduciary powers. (Control Number 96CE01015), 04/24/96
202 Barnett Bank of Jacksonville, N.A., Jacksonville, FL, operating subsidiary notification. (Control Number 96SE080002), 04/25/96

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 96-58, announcing the availability of enforcement actions. Copies of the final actions are available by writing to the Communications Division, OCC, Washington, D.C. 20219. When ordering, specify the appropriate Enforcement Action Number.

Community Reinvestment Act (CRA) Performance Evaluations

Enclosed is a list of CRA performance evaluations that became public during the period of April 15 through May 14.

INTERPRETATIONS AND ACTIONS is published monthly by the Office of the Comptroller of the Currency. Subscriptions are available at a rate of $175 per year by writing to the Comptroller of the Currency, P.O. Box 73150, Chicago, IL 60673-7150. Prepayment is requested.

Suggestions, comments or questions may be sent to Jacqueline J. England, Communications Division, Comptroller of the Currency, Washington, DC 20219.