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Interpretations and Actions: March 2005

Vol. 18, No. 3

Interpretive Letters

Letter No. Topic
1018 Letter concludes that national bank may enter into equity derivatives transactions with certain of its affiliates and subsidiaries that mirror the affiliates' and subsidiaries' transactions with their customers, and may hedge this risks of those transactions in the same manner as it hedges the risks of its existing derivatives business, provided the bank's EIC has no supervisory objection. 02/10/2005
1019 Letter concludes that national bank may offer agricultural loans with payments that vary based on changes in commodity prices. 02/10/2005
1020 Letter concludes that national bank directors may meet the qualifying shares requirement under 12 U.S.C. Section 72 by purchasing trust preferred stock. 02/08/2005
1021 Letter concludes that fixed rate annuities purchased by a national bank are, in substance, debt obligations of the issuing insurance company. 02/17/2005
1022 Letter states that it is permissible for national banks to participate in a group to self-insure group members' workers' compensation obligations. 02/15/2005
1023 Letter states that it is permissible for bank to provide consulting and advisory services to deposit customers who hire independent messenger or courier services to transport banking items to and from the bank. 02/24/2005

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

Letter No. Topic
676 Application from First American Bank, SSB, Bryan, Texas, to convert to a national bank with the title "Citibank Texas, National Association," to be located in Dallas, Texas. (Control Number 2004 ML 01 0005), 02/15/2005

Charters with Standard Conditions

Letter No. Topic
677 Application to charter SONABANK, N.A., Charlottesville, Virginia. (Control Number 2004 SO 01 0021), 02/17/2005

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2005-33, announcing the availability of enforcement actions. Copies of the final actions are available by writing to the OCC, Public Information Room, Mail Stop 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 15, 2005 through March 14, 2005.

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.