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Interpretations and Actions: January 2001

Vol. 14, No. 1

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
900 Bank being identified in publicity as donor of item in fundraising raffle does not violate prohibition on publicizing of lotteries. 06/19/2000
901 Bank may retain shares of stock in life insurance company that it received as a result of being policyholder of mutual company that converted to stock form. 06/29/2000
902 Loan approval is permissible and occasional receipt of misdirected loan payments are permissible at an LPO without making it a branch. 11/16/2000
903 Letter approves credit card "debt suspension agreements," which freeze a cardholder's account for up to 24 months (up to 3 months for a leave of absence) in the event that the cardholder becomes involuntarily unemployed, hospitalized, disabled, or takes a voluntary leave of absence from work. During a "freeze," the cardholder is not charged interest or fees. 12/28/2000

Corporate Decisions

Letter No. Topic
2001-01 Notice of Change in Bank Control involving First National Bank, San Diego, California's proposed acquisition of Generations Trust Bank, National Association, Long Beach, California. (Control Number 2000 WE 11 0003), 12/28/2000

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

Letter No. Topic
434 Application by Worth National Bank, Lake Worth, Texas, to elect the corporate governance provisions of Texas law and complete a reverse stock split in accordance with those provisions. (Control Number 1999 SW 12 0247), 12/15/2000
435 Application by Enterprise National Bank to acquire an operating subsidiary, Select Systems, Inc., to provide employee outsourcing and other human resources services. (Control Number 2000 SE 08 058), 12/18/2000
436 Application by Hemisphere National Bank, Miami, Florida, to own a minority interest in a Florida corporation,, that will facilitate trade financing between U.S. exporters and Latin American importers. (Control Number 2000 SE 08 0036), 12/20/2000
437 Application by Bank One, N.A., Columbus, Ohio, to issue $300 million of trust preferred capital. (Control Number 2000 ML 12 0478), 12/22/2000
438 Application by The Vanguard Group to charter a national CEBA trust bank with the title of "Vanguard National Trust Company, National Association," Valley Forge, Pennsylvania. (Control Number 2000 SE 01 0023), 12/26/2000
439 Application by Neuberger Berman, Inc. to establish a new national trust bank with the title of "Neuberger Berman National Trust Company," Seattle, Washington. (Control Number 2000 WE 01 0020), 12/28/2000
440 Application to merge Midland Interim Trust Company, National Association, Midland, Texas, into and under the charter and title of "Wells Fargo Bank Texas, National Association," San Antonio, Texas. (Control Number 2000 ML 02 0026), 12/29/2000
441 Application by Wells Fargo Bank Texas, National Association, San Antonio, Texas, to purchase and assume certain of the assets and liabilities of The Chase Manhattan Bank, New York, NY. (Control Number 2000 ML 02 0023), 12/29/2000

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
442 Bank of Evansville, National Association, Evansville, Indiana, (Control Number 2000 ML 01 0014), 12/11/2000
443 THE National Bank, Bettendorf, Iowa, (Control Number 2000 CE 01 015), 12/14/2000
444 American National Bank, Lincoln, Nebraska, (Control Number 2000 MW 01 0016), 12/21/2000

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2001-2, 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 December 15 through January 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.