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Interpretations and Actions: April 2000

Vol. 13, No. 4

PLEASE NOTE: Interpretive Letters and No-Objection Letters reflect the views of the Comptroller's legal staff. Corporate Decisions, CRA Decisions and Conditional Approvals are from the office of Bank Organization and Structure. The list of CRA Ratings is from the Communications Division. For copies of the CRA evaluations, you may either contact the bank directly, or you may write to the Office of the Comptroller of the Currency (OCC) in any of three ways: by mail to the OCC, Attn: Public Information Room, Mail Stop 1-5, Washington, D.C. 20219; by fax to (202) 874-4448; or by e-mail to You may also write to the OCC for copies of enforcement actions and charters with standard conditions.

Members of the news media are encouraged to cite the letter number when reporting or summarizing documents from this package. This helps us to process single requests based upon your citation in a more timely manner.

Interpretive Letters

Letter No. Topic
882 Letter advises that a national bank may rely on OCC precedents to establish the permissibility of satellite offices of its insurance agency operating subsidiary in Kentucky and Florida and that, to the extent that the agency's situation is fundamentally the same as those addressed in previous OCC letters, the agency is authorized, under 12 USC 92, to operate the satellite offices. 02/22/2000
883 Letter approves national bank acquisition of non-controlling interest in limited liability company which will enter into contracts with federal, state, and local governments and agencies to provide a package of Internet-based services, including (1) developing Web sites that facilitate electronic procurement transactions, (2) hosting these Web sites, and (3) providing related merchant processing services. 03/03/2000
884 Letter concurs with the bank's view that 12 CFR 9.18(a)(2)(ii) permits the investment of assets of tax-exempt employee benefit accounts held by the bank "in any capacity (including agent)" in part 9 collective investment funds, provided the fund itself is exempt from federal taxation. 01/13/2000
885 Letter relieves Mellon Bank, N.A. from certain commitments and certain conditions of approval noted in the OCC's May 4, 1994 approval letter permitting the Bank to acquire the Dreyfus Corporation. 03/20/2000
886 Letter concludes that a bank's subsidiary may continue underwriting credit-related insurance products under the "authorized product" exception of section 302 of the Gramm-Leach-Bliley Act. 03/27/2000

Corporate Decisions

Letter No. Topic
2000-03 Applications involving Family Bank, FSB, Haverhill, Massachusetts; Bank of New Hampshire, Manchester, New Hampshire; Farmington National Bank, Farmington, New Hampshire; Granite Savings Bank and Trust Company, Barre, Vermont; The Howard Bank, N.A., Burlington, Vermont; Franklin Lamoille Bank, St. Albans, Vermont; and First Vermont Bank and Trust Company, Brattleboro, Vermont. (Control Numbers 2000 NE 01 0004 - 006 & 2000 NE 02 0003 - 00532), 03/08/2000
2000-04 Applications by Norwest Bank South Dakota, N.A., Sioux Falls, South Dakota; Norwest Bank Iowa, N.A., Des Moines, Iowa; and Wells Fargo Bank, N.A., San Francisco, California, to expand the activities of their operating subsidiaries. (Control Numbers 2000 ML 08 003 - 005), 03/23/2000
2000-05 Applications by NBC Bank, FSB, Knoxville, Tennessee, to convert to a national bank charter and by National Bank of Commerce , Memphis, Tennessee, to acquire the converted bank through merger. (Control Numbers 2000 SE 01 0003 & 2000 SE 02 0004), 03/28/2000

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

Letter No. Topic
368 Application to charter PointPath Bank, National Association, Columbus, Georgia. (Control Number 1999 SE 01 0022), 04/03/2000
369 Application by UMB Bank, National Association, Kansas City, Missouri to expand the activities in an existing operating subsidiary by investing in an entity to be known as LLC. (Control Number 1999 MW 08 0035), 02/25/2000
370 Application by ReliaStar Financial Corp. to charter a national CEBA trust bank with the title of "ReliaStar National Trust Company," Minneapolis, Minnesota. (Control Number 2000 MW 01 0001), 03/08/2000
371 Application by Grange National Bank, Laceyville, Pennsylvania, to expand the activities of its operating subsidiary to make a noncontrolling investment in a limited liability partnership that will engage in title insurance sales. (Control Number 2000 NE 08 0001), 03/20/2000
372 Application by HBW, Inc. to charter a national CEBA trust bank with the title of "Security National Trust Company," Wheeling, West Virginia. (Control Number 1999 NE 01 0030), 03/27/2000
383 Application to charter Hutton National Bank, Santa Ana, California. (Control Number 1999 WE 01 0006), 04/13/2000

Charters with Standard Conditions

Each of the following charter application(s) were approved with a standard condition enforceable under 12 U.S.C. 1818 that requires the bank, during the first three years of its operation, to provide notice to the OCC in advance of any significant deviations or changes from its proposed operating plan.

Letter No. Topic
373 InterBusiness Bank, National Association, Los Angeles, California (Control Number 1999 WE 01 0014), 03/15/2000
374 SouthernBank, National Association, Buford, Georgia, (Control Number 1999 SE 01 0032), 03/15/2000
375 First Retail Bank, National Association, Flowery Branch, Georgia, (Control Number 1999 SE 01 0030), 03/17/2000
376 Bank of Powhatan, National Association, Powhatan, Virginia, (Control Number 1999 SE 01 0016), 03/21/2000
377 American National Bank, Sac City, Iowa, (Control Number 2000 MW 01 003), 03/23/2000
378 SunBank, N.A., Murrells Inlet, South Carolina, (Control Number 1999 SE 01 0031), 03/23/2000
379 First National Bank of Spartanburg, Spartanburg, South Carolina, (Control Number 1999 SE 01 0019), 03/27/2000
380 Commerce Bank of Santa Barbara, National Association, Santa Barbara, California, (Control Number 1999 WE 01 0015), 03/27/2000
381 First Trust Company of Onaga, National Association, Onaga, Kansas, (Control Number 1999 MW 01 0004), 03/31/2000
382 Talbots Classics National Bank, Lincoln, Rhode Island, (Control Number 1999 NE 01 0032), 03/31/2000

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2000-30, 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 March 15 through April 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, Mailstop 3-2, Comptroller of the Currency, Washington, DC 20219.