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Interpretations and Actions: March 2002

Vol. 15, No. 3

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
926 Letter concludes that it is permissible to hold equity securities in the separate account of variable life insurance purchased in connection with bank employee compensation and benefit plans if the hedging requirements of Bulletin 2000-23 are satisfied. 09/07/2001
927 Letter states that bank repurchase of credit card loans from securitization constitutes implicit recourse where bank exercises discretion (beyond contractual obligation) to repurchase loans that default on first payment under fraud provision in securitization agreement. 10/29/2001
928 National bank may provide hosting and design services for commercially enabled Web sites and may provide software and web configurations that enable Internet merchants to acquire and compile information from their end clients that will be used for authentication and to support future transactions over the Web site. 12/24/2001
929 Letter concludes it is legally permissible for a national bank's London branch to join the London Clearinghouse to clear interest derivative contracts under national banking law, subject to the concurrence of supervisory staff that the activity can be conducted in a safe and sound manner, or under Regulation K. 02/11/2002

Corporate Decisions

Letter No. Topic
2002-4 Operating subsidiary applications by Bank of America, N.A., Citibank, N.A. and Wells Fargo Bank, N.A. to expand the activities of Indentrus, LLC. (Control Numbers 2001 ML 08 0010, 0011, & 0012), 02/18/2002

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
515 Family Capital Trust Company, National Association, Boston, Massachusetts, (Control Number 2000 NE 01 024), 03/01/2002

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2002-27, 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 February 14 through March 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.