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Interpretations and Actions: January 2003

Vol. 16, No. 1

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
949 Letter confirms that a national bank may engage in certain equity derivatives transactions if the transactions are part of the bank's customer-driven, non-proprietary financial intermediation business and if the bank has in place an appropriate risk measurement and management process 09/19/2002
950 Letter addresses the interaction of the legal lending limit and 371D. Bank proposes to make a loan to an unrelated entity that will construct a new bank building. The amount of the loan would exceed the bank's 15 % general lending limit. However, under 371D, a national bank may invest in bank premises and make loans to any corporation holding the premises of the bank in an amount not to exceed 100% of the bank's capital stock (absent certain other requirements being satisfied). The letter concludes that the more specific statute, 371D, controls over the more general LLL statute. 12/18/2002

Corporate Decisions

Letter No. Topic
2003-1 Application of American National Bank, Gonzales, Texas to purchase certain assets and assume certain liabilities of the Gonzales, Texas branch of Guaranty Federal Bank, FSB, Dallas, Texas. (Control Number 2002 SW 02 0028), 12/05/2002

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

Letter No. Topic
560 Application to merge The Glenmede Trust Co, Philadelphia, Pennsylvania, and The Glenmede Trust Company of NJ, Princeton, New Jersey, with and into The Glenmede Trust Co NA, Philadelphia, Pennsylvania with the charter number and title of "The Glenmede Trust Company, National Association." (Control Number 2002 NE 02 0030), 12/03/2002
561 Application by BPABank, National Association, Newark, New Jersey, to purchase certain assets and assume certain liabilities of the Springfield branch of Woronoco Savings Bank, Westfield, Massachusetts. (Control Number 2002 NE 02 0026), 12/06/2002
562 Application by First American National Bank, Iuka, Mississippi to elect the corporate governance provisions of Mississippi law and complete a reverse stock split in accordance with those provisions. (Control Number 2002 SE 12 136), 12/09/2002
563 Application to convert Security Trust Company, Phoenix, Arizona, to a national bank with the title of "Security Trust Company, National Association." (Control Number 2002 WE 01 0005), 12/16/2002
564 Application to convert Northwestern State Bank, Hallock, Minnesota, to a national bank with the title of "Marshall Bank, National Association" and for the converted bank to establish a branch office in Minneapolis, Minnesota. (Control Numbers 2002 MW 01 0012 & 2002 MW 05 0090), 12/17/2002
565 Applications by UBS AG to convert two state branches located in New York, New York to Federal branches; convert a state agency in Miami, Florida to a limited Federal branch; establish an additional limited Federal branch in New York, New York; and exercise fiduciary powers. (Control Numbers 2002 IB 10 0003, 0004, 0005, 0006 & 2002 IB 12 0006), 12/23/2002
566 Application to establish a new national trust bank to engage solely in fiduciary activities with the title of "Merchants Trust Company, National Association." (Control Number 2002 CE 01 006), 12/23/2002
567 Application to merge Trust Company of Maine, Inc., Bangor, Maine, with and into Acadia Trust, National Association, Portland, Maine. (Control Number 2002 NE 02 0034), 12/24/2002
568 Applications of Central National Bank and Trust Company of Enid, Enid, Oklahoma to establish two operating subsidiaries engaged in payments activities. (Control Numbers 2002 SW 08 0015 & 2002 WO 08 0007), 12/31/2002

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
569 Application to charter Liberty National Bank, Sioux City, Iowa. (Control Number 2002 MW 01 010), 12/19/2002

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2003-04, 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 December 15, 2002 through January 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.