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Interpretations and Actions: May 2001

Vol. 14, No. 5

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
907 Letter concludes that Housing Mortgage Finance Program Bonds issued by the Connecticut Housing Finance Authority would qualify as Type I securities and therefore would be subject to a 20 percent risk-weight. 02/01/2001
908 Letter confirms that trust preferred securities issued by the holding company for a bankers bank may be purchased and held as loans by national banks, subject to the lending limits of 12 U.S.C. 84 and the requirements of Banking Circular 181 (REV). 04/23/2001
909 Letter concerns a non-controlling equity interest held by a national bank in a corporation that plans to provide employee benefit services and payroll services to small community banks and their small business customers. 05/02/2001

Corporate Decisions

Letter No. Topic
2001-07 Applications by Exchange National Bank, Moore, Oklahoma, to establish a branch at 517 North Telephone Road, Moore, Oklahoma, and two operating subsidiaries to be named ENB Real Estate Company and ENB Finance Company. (Control Numbers 2000 SW 05 0163 & 2000 SW 08 0029), 04/02/2001
2001-08 Application to purchase the assets and assume the liabilities of the Fredonia branch of Commercial Federal Bank, FSB, Omaha, Nebraska, by Community National Bank, Chanute, Kansas. (Control Number 2001 MW 02 012), 04/10/2001
2001-09 Application to charter a national bank with the title of "Security National Bank," Spartanburg, South Carolina. (Control Number 2000 SE 01 012), 04/18/2001
2001-10 Application by Bank One, N.A., Columbus, Ohio, to expand the activities of its operating subsidiary, Congress Life Insurance Company, to include reinsuring credit life and credit-related health and disability insurance in connection with loans to customers made by the bank and affiliated and unaffiliated lenders. (Control Number 2001 ML 08 0005), 04/23/2001

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

Letter No. Topic
459 Application to charter World's Foremost Bank, National Association, Sidney, Nebraska. (Control Number 2000 MW 01 12), 03/23/2001
460 Significant change in the operating plan for California First National Bank, Santa Ana, California (formerly known as Hutton National Bank). (Control Number 1999 WE 01 0006), 04/03/2001
461 Application to establish a new national bank with the title of "BNC National Bank of Arizona," Tempe, Arizona. (Control Number 2001 MW 01 003), 04/04/2001
462 Applications to convert Treasury Bank, Ltd., Washington, DC, into a national banking association, to merge an interim national bank, Treasury Bank Interim, National Association, Washington, DC, with and into Treasury Bank Ltd., to relocate Treasury Bank Ltd. to Alexandria, Virginia and to change its name to "Effinity Bank, National Association." (Control Numbers 2000 NE 01 0026 , 2000 NE 02 0025 & 2000 NE 07 0037), 04/04/2001
463 Proposal to merge Peoples and Union Bank, Lewisburg, Tennessee, into First Farmers and Merchants National Bank of Columbia, Columbia, Tennessee. (Control Number 2000 SW 02 0043), 04/06/2001
464 Application by CNB National Bank, Lake City, Florida, to purchase two branches of Republic Bank, St. Petersburg, Florida. (Control Number 2001 SE 02 0003), 04/24/2001
465 Application to establish a full service national bank with the title of "American Home Bank, National Association," Lancaster, Pennsylvania. (Control Numbers 2001 NE 01 001 & 2001 NE 08 004), 04/26/2001
466 Application to establish Boone National Bank, Burlington, Kentucky. (Control Number 2000 CE 01 011), 04/27/2001

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
467 First National Bank of Muskogee, Muskogee, Oklahoma, (Control Number 2000 SW 01 0022), 04/10/2001
468 CommerceWest Bank, N.A., Newport Beach, California, (Control Number 2000 WE 01 026), 04/27/2001

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2001-47, 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 April 15 through May 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.