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Interpretations and Actions: August 2001

Vol. 14, No. 8

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
911 Letter concludes that national banks may acquire for their own account beneficial interests in a privately offered investment fund that would invest in loans, cash and cash equivalents, and an offshore fund that invests solely in loans. 06/04/2001
912 Letter concludes that a mutual fund containing general obligation and municipal revenue bonds: [1] is a permissible investment for national banks under 12 CFR Part 1.3(h)(2), [2] has a risk-weight dependent on the composition of the fund's assets, but in no event will the minimum risk-weight be less that 20%, and [3] can be accounted for as either a "trading" or "available-for-sale" asset. 07/03/2001
913 Letter holds that a national bank debtor is located in the state in which its main office is located, for purposes of section 9-307(f) of revised Article 9 of the UCC. 08/06/2001

CRA Decisions

Letter No. Topic
109 Merger applications of Firstar Bank, National Association, Cincinnati, Ohio; U.S. Bank National Association, Minneapolis, Minnesota; U.S. Bank National Association, Canby, Oregon; and U.S. Bank National Association, MT, Billings, Montana. (Control Numbers 2001 CE 02 0022 - 24), 7/18/2001

Corporate Decisions

Letter No. Topic
2001-18 Application by Business First National Bank, Santa Barbara, California, to establish an operating subsidiary to acquire E-Commerce Financial Services. (Control Number 2001 MW 08 011), 07/03/2001
2001-19 Application by First National Bank, Julesburg, Colorado, to purchase the assets and assume the deposit liabilities of the Julesburg branch of Bank of Colorado, Fort Lupton, Colorado. (Control Number 2001 WE 02 0017), 07/11/2001
2001-20 Notices of Change in Bank Control involving Pell Rudman Trust Company, N.A., Boston, Massachusetts, and Pell Rudman Trust Company (Atlantic), N.A., Washington, D.C. (Control Numbers 2001 SE 11 0001 & 0002), 07/16/2001
2001-21 Application of Bank of Powhatan, N.A., Powhatan, Virginia, to undertake a reorganization pursuant to Section 1204 of the American Home Ownership and Economic Opportunity Act of 2000 and 12 CFR 7.2000(a). (Control Number 2001 SE 12 081), 07/26/2001
2001-22 Application to merge Banc One Mortgage Corporation and First Chicago NBD Mortgage Company into Bank One, National Association, Columbus, Ohio. (Control Numbers 2001 ML 02 0023 & 2001 ML 12 0232), 07/26/2001

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

Letter No. Topic
476 Application to merge European American Bank, Uniondale, New York, into and under the charter and title of Citibank, National Association, New York, New York. (Control Number 2001 ML 02 0006), 07/02/2001
477 Application to establish a new national bank with the title of Premier Commercial Bank, National Association, Anaheim, California. (Control Number 2001 WE 01 0005), 07/27/2001

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
478 Islands Community Bank, National Association, Beaufort, South Carolina, (Control Number 1999 SE 01 026), 07/09/2001

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2001-70, 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 July 15 through August 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.