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Interpretations and Actions: August 1998

Vol. 11, No. 8

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. For copies of the evaluation, you should contact the bank directly or the Office of the Comptroller of the Currency, Attn: Public Reference Room, Mailstop 1-5, Washington, D.C. 20219.

Members of the news media are encouraged to 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
832 Letter overrules Interpretive Letter #617 and permits national banks to invest in a SBIC that is in organization. (06/18/98)
833 Letter concludes that national banks have the authority to purchase performance notes (Notes) in which the yield on the Notes is based upon the performance of a pool of mortgage made by the bank. (07/08/98)
834 Letter finds that performance note loans to be issued by mortgage insurer are not investment securities, but may qualify as loans eligible for purchase by national banks. (07/08/98)
835 Letter concludes that a national bank's ownership of a non-controlling interest in an insurance company that reinsures mortgage life, mortgage accidental death, and mortgage disability insurance on loans originated by the lenders with an ownership interest in the insurance company is permissible. (08/03/98)

CRA Decisions

Letter No. Topic
81 Application of First of America Bank, National Association, Kalamazoo, Michigan, to merge with First of America Bank-Illinois, National Association, Bannockburn, Illinois, with the resulting title of National City Bank of Michigan/Illinois; (Control Number 98CE020015), (07/14/98).

Corporate Decisions

Letter No. Topic
98-38 Change in bank control notification by Dillard's Inc. involving Mercantile Stores National Bank, Baton Rouge, Louisiana; (Control Number 98WE11002), (07/22/98).

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

Letter No. Topic
281 Application by Firstar Bank Milwaukee, National Association, Milwaukee, Wisconsin, for approval to acquire Cargill Leasing Corporation as an operating subsidiary. (Control Number 98CE08020), 07/30/98
282 Application by NationsBank, National Association, Charlotte, North Carolina, to establish an operating subsidiary, NationsBanc Health Services, Inc., that will acquire a one-half, non-controlling equity interest in Electronic Health Services, L.L.C. (Control Number 98ML080006), 07/31/98

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 98-91, announcing the availability of enforcement actions. Copies of the final actions are available by writing to the OCC, Public

Reference Room, Mailstop 1-5, 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 July 15 through August 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 70004, Chicago, IL 60673-0004. Prepayment is requested. Suggestions, comments or questions may be sent to Jacqueline J. England, Communications Division, Comptroller of the Currency, Washington, DC 20219.