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Interpretations and Actions: April 2005

Vol. 18, No. 4

Interpretive Letters

Letter No. Topic
1024 Letter concludes that a national bank that renews a loan to an insider violates section 215.4(a)(1) of Regulation O and section 22(h)(A) of the Federal Reserve Act if the loan either (i) is preferential or (ii) involves more than the normal risk of repayment or presents other unfavorable features. 03/21/2005
1025 Letter concludes that it is permissible for a national bank to engage in customer-driven electricity derivative transaction and hedges, settled in cash and by transitory title transfer, as activities part of, or incidental to, bank permissible financial intermediation transactions. 04/06/2005

Corporate Decisions

Letter No. Topic
2005-01 Change in Bank Control Act notices in connection with the proposed acquisition of First National Bank of Marin, Las Vegas, Nevada, by Sherman Financial Group LLC, Radian Group, Inc., and MGIC Investment Corporation. (Control Numbers 2004 WE 11 0010, 0011 and 0012), 03/04/2005
2005-02 Operating subsidiary application by JPMorgan Chase Bank, N.A., New York, New York to acquire Vastera, Inc. (Control Number 2005 ML 08 0001), 03/24/2005

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

Letter No. Topic
678 Application to convert Investors Trust Company, Wyomissing, Pennsylvania, into a limited purpose national trust bank to be title "National Penn Investors Trust Company" and become a subsidiary of National Penn Bank, Boyertown, Pennsylvania. (Control Number 2004 NE 01 0011), 03/22/2005
679 Application by Treasury Bank, National Association, Alexandria, Virginia, to increase its capital surplus by up to $300 million. (Control Number 2005 WE 12 0058), 03/22/2005
680 Application to convert Valley Independent Bank, El Centro, California, to a national bank with the title of "Rabobank, National Association" and retain all of its branches. (Control Number 2004 WE 01 0026), 03/29/2005

Charters with Standard Conditions

Letter No. Topic
681 Application to charter Saigon National Bank, Westminster, California. (Control Number 2004 WE 01 0022), 03/14/2005

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2005-38, 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, 2005 through April 14.

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 Licensing. The Community Development Investment Letters are from the office of Community Affairs. 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 timelier manner.

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, ATTN: Accounts Receivable, Mail Stop 4-8, 250 E Street, S.W., Washington, DC 20219. Prepayment is requested. Suggestions, comments or questions may be sent to Jacqueline J. England, Comptroller of the Currency, Communications Division, Mail Stop 3-2, Washington, DC 20219.