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Interpretations and Actions: February 2000

Vol. 13, No. 2

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
879 Letter finds that a national bank may elect the corporate governance provisions of Virginia law and complete a share exchange in accordance with those provisions. 11/10/1999
880 Letter considers the permissibility of certain investment advisory and related intermediary services provided in connection with the exchange of existing investment real estate in a bank client's portfolio for "like kind" investment real estate in a tax-free exchange under the Internal Revenue Code Section 1031. Based on the Bank's representations, the letter finds that a bank, as incidental to the real estate investment advisory services, may take part in negotiating the 1031. 12/16/1999
881 Letter describes how a national bank using multiple trade names over the Internet can comply with the Interagency Statement on Branch Names (which provides guidance for banks using multiple trade names and suggests certain steps to prevent customer confusion and to reduce transaction and compliance risk). 01/14/2000

Corporate Decisions

Letter No. Topic
2000-1 Application by EFS National Bank, Memphis, Tennessee to acquire Virtual Cyber Systems, Inc., as a wholly -owned operating subsidiary. (Control Number 1999 SE 08 0046), 01/29/2000

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

Letter No. Topic
348 Application to charter an uninsured national trust bank with the title of "FIRSTFED TRUST COMPANY, National Association," Swansea, Massachusetts. (Control Number 1999 NE 01 0019), 11/22/1999
349 Application by First National Bank of Eagle Lake, Eagle Lake, Texas, to establish a domestic branch in East Bernard, Wharton County, Texas. (Control Number 1999 SW 05 0238), 01/10/2000
350 Application by Commerce Bank/Delaware, National Association, Wilmington, Delaware, to establish a branch at 9th and Shipley Streets, Wilmington, Delaware. (Control Number 1999 NE 05 0085), 01/28/2000
351 Application by First Tennessee Bank, National Association, Memphis, Tennessee, to expand the activities of its operating subsidiary, First Tennessee Securities Corporation, to underwrite and deal in all types of debt and equity securities (other than interests in open-end investment companies). (Control Number 1999 WO 08 0015), 01/28/2000

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 at least 30 days in advance of any significant deviations or changes from its proposed operating plan.

Letter No. Topic
352 Greenville First Bank, National Association, Greenville, South Carolina, (Control Number 1999 SE 01 010), 01/11/2000
353 Heber Valley National Bank, Heber City, Utah, (Control Number 1999 WE 01 0017), 01/13/2000
354 United National Bank, Cairo, Georgia, (Control Number 1999 SE 01 0025), 01/18/2000
355 Fulton Financial Advisors, National Association, Lancaster, Pennsylvania, (Control Number 1999 NE 01 0024), 01/19/2000
356 NorthStar Bank, National Association, Kansas City, Missouri, (Control Number 1999 MW 01 015), 01/20/2000
357 Professional National Bank, Las Vegas, Nevada, (Control Number 1999 WE 01 008), 01/28/2000

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2000-14, 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 January 15 through February 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.