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Interpretations and Actions: July 2002

Vol. 15, No. 7

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
938 Letter states that when a national bank makes loans to two entities related through common control ("A" & "B") and A and B each pays more than 50% of its gross annual expenditures to a third related entity ("X"), substantial financial interdependence exists and the loans to A & B will be attributed to X under 12 C.F.R. 32.5(c)(2) and thus combined for purposes of the legal lending limit, even where X does not borrow directly from the national bank. 01/18/2001
939 Letter concludes that federal law would preempt laws in Massachusetts and Florida that purport to limit or restrict a national bank from establishing deposit-taking ATMs. 10/15/2001
940 Letter confirms that a national bank may acquire for limited periods of time, limited interests in private investment funds for which it serves as investment manager. 05/24/2002

Corporate Decisions

Letter No. Topic
2002-09 Application to purchase certain assets and assume the liabilities of the Vandalia, Illinois branch of Fifth Third Bank, Indiana, Indianapolis, Indiana, by The First National Bank, Vandalia, Illinois. (Control Number 2002 MW 02 0010), 06/24/2002
2002-10 Application to purchase certain assets and assume certain liabilities of the Taylor, Giddings & Rockdale branches of International Bank of Commerce, Laredo, Texas, by Citizens National Bank of Milam County, Cameron, Texas. (Control Number 2002 SW 02 0014), 06/26/2002
2002-11 Operating subsidiary application by Extracto Bank, N.A., Waco, Texas, to expand the activities of Extract Institutional Services Corp. (Control Number 2002 WO 08 0002), 06/28/2002

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

Letter No. Topic
533 Application to establish a new national bank with the title of "First Commerce Bank, National Association," Marysville, Kansas. (Control Number 2001 MW 01 007), 06/06/2002
534 Application to establish a new national bank with the title of "Community National Bank," Bellaire, Texas. (Control Number 2001 SW 01 00006), 06/13/2002
535 Operating subsidiary application of Citibank USA, N.A., New York, New York to acquire three subsidiaries that operate and administer automotive roadside assistance programs and to acquire a fourth subsidiary that provides credit card registration and notification services. (Control Number 2001 ML 08 0022), 06/21/2002
536 Operating subsidiary application by Bank of America, National Association, Charlotte, North Carolina, to facilitate an additional funding source for the Bank's mortgage business. (Control Number 2002 ML 08 0012), 06/21/2002
537 Application for Household Bank (SB) N.A., Las Vegas, Nevada, to purchase and assume assets of Beneficial National Bank USA, New Castle, Delaware. (Control Number 2002 WO 02 0003), 06/26/2002; and
Application for Household Bank (Nevada) N.A., Las Vegas, Nevada, to merge with and into Household Bank (SB) N.A., Las Vegas, Nevada. (Control Number 2002 WE 02 0003), 06/26/2002

Charters with Standard Condition

Each of the following charter application(s) were approved with a standard condition enforceable under 12 U.S.C. 1818 that requires the bank to provide notice and obtain OCC's non-objection in advance of any significant deviations or changes from its business plan or operations.

Letter No. Topic
538 Application to charter Community National Bank, Monett, Missouri. (Control Number 2002 MW 01 002 & 2002 MW 05 027), 06/12/2002

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2002-57, 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 June 14 through July 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.