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Interpretations and Actions: December 2000

Vol. 13, No. 12

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
898 Letter confirms that a national bank may lawfully acquire and hold a ten to twenty percent non-controlling equity interest in a holding company engaged in the origination, purchase and securitization of prime auto leases. 07/14/1998
899 Loans guaranteed by the Illinois Farm Development Authority (IFDA) qualify for the lending limit exception contained in 12 CFR 32.3(c)(5) because of an Illinois Attorney General Opinion stating that IFDA loan guarantees are backed by the full faith and credit of the State of Illinois. Letter also states that national banks may rely on the Illinois Attorney General opinion instead of obtaining their own opinion of counsel as required by the regulation. 05/15/2000

Corporate Decisions

Letter No. Topic
2000-21 Notice by Citigroup Inc. of its intent to acquire a controlling interest in Associates National Bank (Delaware), Newark, Delaware. (Control Number 2000 ML 11 0001), 11/30/2000
2000-22 Application by the First National Bank of Lawrence County, Walnut Ridge, Arkansas, to establish a branch at 300 SW Texas Street, Hoxie, Arkansas. (Control Number 2000 SE 05 0120), 11/07/2000

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

Letter No. Topic
424 Application to establish a new national CEBA credit card bank with the title of "World's Foremost Bank, National Association," Sidney, Nebraska. (Control Number 2000 MW 01 12), 11/07/2000
425 Application to merge Institutional Trust Company, Denver, Colorado, with AMVESCAP National Trust Company (an interim national bank), Atlanta Georgia. (Control Number 2000 SE 02 0019), 11/08/2000
426 Application to establish a new national trust bank with the title of "First Community Trust, National Association," Dubuque, Iowa. (Control Number 2000 MW 01 0011), 11/09/2000
427 Application to establish a new national bank with the title of "Bridge Bank of Silicon Valley, National Association," Santa Clara, California.(Control Number 2000 WE 01 0018), 11/17/2000

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
428 Bank of America Georgia, National Association, Atlanta, Georgia, (Control Number 2000 ML 01 0006, 11/01/2000
429 Heritage Bank, National Association, Doniphan, Nebraska, (Control Number 2000 MW 01 0014), 11/03/2000
430 eComm National Bank, Irvine, California, (Control Number 2000 WE 01 017), 11/13/2000
431 First National Bank of Gwinnett, Duluth, Georgia, (Control Number 1999 SE 01 023), 11/14/2000
432 SunBank, National Association, Murrells Inlet, South Carolina, (Control Number 1999 SE 01 031), 11/15/2000
433 Commonwealth National Bank, Worcester, Massachusetts, (Control Number 2000 NE 01 0022, 11/21/2000

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2000-103 , 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 November 15 through December 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.