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Interpretations and Actions: April 2003

Vol. 16, 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
960 Joint agency letter clarifying that Gramm-Leach-Bliley Act (GLBA) section 305 and the agencies' implementing regulations do not mandate that banks provide disclosures for renewals of insurance policies sold prior to October 1, 2001. 02/28/2003
961 Letter confirms that it is legally permissible for a national bank to purchase and hold options on the shares of stock of a company when the bank has acquired shares in satisfaction of debt previously contracted (DPC). The bank would hold the options to hedge the market risk associated with changes in the value of the DPC shares. 03/17/2003

Corporate Decisions

Letter No. Topic
2003-2 Notice of Change in Bank Control by HSBC Holdings plc (HSBC) with respect to Household Bank (SB) National Association, Las Vegas, Nevada. (Control Number 2002 WE 11 0004), 03/27/2003
2003-3 Application on behalf of Mellon 1st Business Bank, Los Angeles, California to convert to a national bank with the title "Mellon 1st Business Bank, National Association." (Control Number 2002 NE 01 0011), 03/03/2003
2003-4 Application by South Texas National Bank, Laredo, Texas to purchase the assets and assume the liabilities of the Eagle Pass, Texas branch of Sterling Bank, Houston, Texas. (Control Number 2002 SW 02 0032), 03/04/2003
2003-5 Application of the City National Bank and Trust Company of Guymon, Guymon, Oklahoma to purchase certain assets and assume certain liabilities of the Guymon, Oklahoma branch of Gold Bank, Hennessey, Oklahoma. (Control Number 2003 SW 02 0002), 03/13/2003
2003-6 Application by Bank One, National Association, Chicago, Illinois to establish an operating subsidiary that will purchase and then sell or license data processing software that performs functions regarding the charges and payments on a corporate credit card. (Control Number 2003 ML 08 0007), 03/17/2003
2003-7 Application by Household Bank (SB), National Association, Las Vegas, Nevada, to purchase substantially all the assets of National Bank of the Great Lakes, Elmhurst, Illinois. (Control Number 2002 WE 02 0023), 03/31/2003

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

Letter No. Topic
581 Application to merge May National Bank of Arizona, Phoenix, Arizona with and into May National Bank of Ohio, Lorain, Ohio under the charter and title of the latter. (Control Number 2003 MW 02 0002), 03/10/2003
582 Operating subsidiary and non-controlling investment applications by First National Bank of Arizona, Scottsdale, Arizona. (Control Number 2003 WE 08 0004), 03/12/2003
583 Operating subsidiary and non-controlling investment applications by First National Bank of Nevada, Reno, Nevada. (Control Number 2003 WE 08 0005), 03/12/2003
584 Application to charter Liberty National Bank, Sioux City, Iowa. (Control Number 2002 MW 01 010), 03/18/2003
585 Proposal by Barclays Global Investors, N.A., San Francisco, California to reduce permanent capital. (Control Number 2003 WE 12 0032), 03/28/2003

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2003-31, 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 15, 2003 through April 14, 2003.

The Office of the Comptroller of the Currency publishes INTERPRETATIONS AND ACTIONS monthly. Subscriptions are available at a rate of $175 per year by writing to the Comptroller of the Currency, P.O. Box 73150, Chicago, IL 60673-7150. Prepayment is requested. Suggestions, comments or questions may be sent to Jacqueline J. England, Communications Division, Comptroller of the Currency, Mail Stop 3-2, Washington, DC 20219.