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Interpretations and Actions: February 2002

Vol. 15, No. 2

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
924 Letter concludes that the OCC will not apply its five percent policy limit on a national bank's holdings of equity securities for hedging purposes to securities held by the bank's Edge corporation subsidiary. 01/02/2002
925 A national bank with four outstanding loans to four separate local churches proposed to lend additional funds to a fifth church. Because the proceeds of loans made to the local churches are used for transactions which are controlled by trusts having an identical beneficiary (the parent church), and this beneficiary is entitled to the ultimate of those transaction, the loans should be combined and attributed to the beneficiary. 04/12/2001

Corporate Decisions

Letter No. Topic
2002-1 Application to merge M&I Marshall & Ilsley Trust Company of Arizona, Scottsdale, Arizona, Marshall & Ilsley Trust Company of Florida, Naples, Florida, and Marshall & Ilsley Trust Company, Milwaukee, Wisconsin, with and into M&I National Trust Company, Milwaukee, Wisconsin, under the charter of the latter and the title of "Marshall & Ilsley Trust Company, National Association." (Control Number 2001 CE 02 0047), 01/02/2002
2002-2 Application by Bank of Lancaster County, N.A., Strasburg, Pennsylvania, to establish an operating subsidiary to provide employee benefit, compensation advisory and related administrative services and other human resource services to the Bank's business customers and other businesses in the Bank's market area. (Control Number 2001 NE 08 0039), 01/09/2002
2002-3 Application by THE National Bank, Bettendorf, Iowa, to establish an Iowa messenger service branch. (Control Number 2001 CE 05 160), 01/16/2002

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

Letter No. Topic
511 Application by The Midway National Bank of St. Paul, St. Paul, Minnesota, to charter a wholly owned subsidiary, "Securian Trust Company, National Association," St. Paul, Minnesota and notice of intent by Securian Financial Group, Inc. To acquire control of STC. (Control Numbers 2001 MW 01 0015, 2001 MW 08 0031, & 2001 MW 11 0006), 01/09/2002

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
512 Community National Bank, Bellaire, Texas, (Control Number 2001 SW 01 0006), 01/04/2002
513 Citizens National Bank, Windsor, Virginia, (Control Number 2001 SE 01 0010), 01/18/2002
514 Grand Bank, National Association, Hamilton, New Jersey, (Control Number 2001 NE 01 0013), 01/24/2002

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2002-11, 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 January 14 through February 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.