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Interpretations and Actions: May 1998

Vol. 11, No. 5

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
826 Letter concludes that national banks may invest in insurance company separate account product, which in turn invests solely in bank-eligible U.S. Treasury, Agency and Government-sponsored enterprise obligations. (03/17/97)
827 Letter approves credit card "debt suspension agreements," which freeze a cardholder's account for up to a specified number of months in the event that the cardholder becomes involuntarily unemployed, is unable to work due to disability, goes on approved family leave, is hospitalized for more than a specified number of days, or becomes temporarily unable to continue to make payments on the account for certain or other specified reasons. During a "freeze" the cardholder is not charged interest or fees. (04/03/98)
828 Letter opines that national bank participation in a mortgage reinsurance exchange is permissible where the exchange will provide for the reinsurance of private mortgage insurance on loans originated or purchased by participating lenders. (04/06/98)
829 Letter concludes that a national bank may charge different management fees to collective investment fund participant, commensurate with the amount and types of services it provides to participants, where the fees, meet the requirements of the reasonableness standard of 12 C.F.R. 9.18(b)(9) and each participant retains a proportionate interest in the collective investment fund's underlying assets as required by 12 C.F.R. 9.18(b)(3). (04/09/98)

Corporate Decisions

Letter No. Topic
98-17 Notification by Girard National Bank, Girard, Kansas, to establish G.N. Resources, Inc.; (Control Number 97MW080048), (03/23/98).
98-18 Application to merge First Commercial Bank, N.A., Memphis, Tennessee, with and into First Commercial Bank, N.A., of West Memphis, West Memphis, Arkansas, and related applications; (Control Numbers 98SW010002 and 98SW020003, -0010, and -0013), (03/25/98).
98-19 Application to merge NationsBank of Texas, National Association, Dallas, Texas, with and into NationsBank, National Association, Charlotte, North Carolina; (Control Number 97ML020038), (04/02/98).
98-20 Application to merge Rhode Island Hospital Trust National Bank, Providence, Rhode Island, with and into BankBoston, National Association, Boston, Massachusetts; (Control Number 98ML020006), (04/02/98).
98-21 Application to merge CoreStates Bank, National Association, Philadelphia, Pennsylvania, with and into First Union National Bank, Charlotte, North Carolina; (Control Number 98ML020005), (04/15/98).
98-22 Application by Fifth Third Bank of Northwestern Ohio, N.A., Toledo, Ohio, of its intent to establish an operating subsidiary to reinsure mortgage insurance; (Control Number 98CE080003), (04/22/98).
98-23 Application to merge PremierBank & Trust, Elyria, Ohio, and Jefferson Savings Bank, West Jefferson, Ohio, with and into FirstMerit Bank, National Association, Akron, Ohio; (Control Number 98CE020004), (04/30/98).
98-24 Notice of Change in Bank Control involving The First National Bank of Keystone, Keystone, West Virginia; (Control Number 98SE110002), (05/04/98).

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

Letter No. Topic
273 Application by Citibank, N.A., New York, New York, to make through an operating subsidiary a minority, non-controlling investment in Integrion Financial Network, L.L.C. (Control Number 97WO080014), 02/26/98
274 Notice of Change in Bank Control involving People's National Bank, Seneca, Missouri. (Control Number 97MW110004, 04/17/98
275 Application by National Penn Bank, Boyertown, Pennsylvania, to establish an operating subsidiary to acquire and hold a 70% non-controlling interest in a limited partnership which will engage in title insurance agency activities. (Control Number 97NE080005), 04/22/98

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 98-53, 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 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 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.