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Interpretations and Actions: April 2002

Vol. 15, No. 4

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
930 Letter concludes a Federal branch's purchase of bonds convertible into equity were permissible investments under Part 1 if the bonds are the credit equivalent of investment grade and marketable. Letter also states that [1] the subsequent sale of a call option on a bond does not affect its marketability, [2] a national bank can purchase bonds convertible into equity where it does not exercise the conversion feature, and [3] while in this case the assignment of a credit rating to the bonds in conjunction with a related asset swap and call option was sufficient to demonstrate an analysis of the bonds, debt securities should be assigned their own separate credit rating. Alternatively, the purchase is permissible under the branch's lending authority if the branch complies with BC-181. 03/11/2002
931 Letter concludes that a national bank may invest in perpetual preferred stock issued by the Federal National Mortgage Association ("Fannie Mae") and by the Federal Home Loan Mortgage Corporation ("Freddie Mac") without limit, subject to safety and soundness considerations. 03/15/2002

CRA Decisions

Letter No. Topic
111 Application to merge Wachovia Bank, National Association, Winston-Salem, North Carolina, into and under the charter of First Union National Bank, Charlotte, North Carolina with the resulting bank title of "Wachovia Bank, National Association". (Control Number 2002 ML 02 0001), 03/01/2002

Corporate Decisions

Letter No. Topic
2002-5 Application to consolidate The Security State Bank, Bird City, Kansas, with First National Bank, Goodland, Kansas under the charter and title of First National Bank. (Control Number 2002 WE 02 0001), 02/21/2002
2002-6 Application of Charter One Bank, F.S.B., Cleveland, Ohio, to convert to a national bank with the title of Charter One Bank, National Association. (Control Number 2002 CE 01 001), 03/13/2002

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

Letter No. Topic
516 Application to charter Charter Bank of Louisa, N.A., Louisa, Virginia. (Control Number 2001 SE 01 00013), 03/15/2002
517 Application to charter United Bank & Trust National Association, Ames, Iowa. (Control Number 2002 MW 01 001), 03/20/2002
518 Application to convert Legacy Trust Company, Houston, Texas, into a national trust bank to be entitled Legacy Trust Company, National Association. (Control Number 2001 SW 01 0010), 03/27/2002
519 Application to charter Carolina National Bank & Trust Company, Columbia, South Carolina. (Control Number 2001 SE 01 0014), 03/28/2002

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2002-36, 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 March 14 through April 15, 2002.

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.