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Interpretations and Actions: October 2000

Vol. 13, No. 10

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
893 Letter states that the proposed total return swap is not subject to a specific risk capital charge for market risk under 12 CFR Part 3, Appendix B but is subject to other requirements of 12 CFR Part 3, Appendix B including the general market risk capital charge. 11/23/1999
894 Letter states that the proposed preferred securities may qualify as bank-level Tier 1 capital up to a maximum of 15% of total Tier 1 capital. 03/10/2000
895 Letter states that a national bank may not qualify loan to customer who operates warehouse/grain elevator for special lending limits of 12 USC 84(c)(3) and 12 CFR 32.3(b)(1)(iv)(B) merely by registering warehouse receipts with independent third party as long as staples remain in control of customer. 06/22/2000
896 Letter states that a national bank may purchase options on futures contracts on commodities to hedge the credit risk in its agricultural loan portfolio. 08/21/2000

Corporate Decisions

Letter No. Topic
2000-17 Applications of Gateway Interim Bank, St. Louis, Missouri, and Gateway National Bank, St. Louis, Missouri. (Control Numbers 2000 MW 02 0017 & 2000 MW 12 0052), 09/20/2000

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

Letter No. Topic
413 Application of Wells Fargo Bank, National Association, San Francisco, California, to establish an operating subsidiary that will engage in certain internal financial transactions already conducted by another subsidiary. (Control Number 2000 ML 08 0024), 09/22/2000
414 Application by Commerce Bank, National Association, Cherry Hill, New Jersey, to establish a branch at 501-505 East Atlantic Avenue, Haddon Heights, New Jersey. (Control Number 2000 WE 12 0082), 08/20/2000

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2000-83, 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 September 15 through October 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.