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Interpretations and Actions: May 2005

Vol. 18, No. 5

Interpretive Letters

Letter No. Topic
1026 Letter concludes that the bank's proposed securities conduit lending services are legally permissible for a national bank. 04/27/2005
1027 Letter confirms that the bank may purchase and hold the preferred securities of two special purpose entities that hold interests in Australian mortgage assets. 05/03/2005
1028 Letter concludes that the OCC would not find a violation of 12 CFR 37.3(a) in connection with a national bank's automobile loan that includes a GAP feature offered by the bank because the OCC views the underlying loan and the GAP feature as a single product, and the financial arrangement does not create a separate product. 05/09/2005

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 & 0012), Sherman Agreement, Operating Agreement, 03/04/2005, (REPUBLISHED WITH AGREEMENTS ATTACHED)

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

Letter No. Topic
682 Direct Merchants Credit Bank, N.A., Phoenix, Arizona, request for reduction of permanent capital. (Control Number 2004 WE 12 0161), 04/06/2005
683 Application by First National Bank of Mayfield, Mayfield, Kentucky under 12 CFR 5.46 to elect the corporate governance provisions of Kentucky law and complete a reverse stock split in accordance with those provisions. (Control Number 2005 SO 12 0020), 04/07/2005
684 Application by Wells Fargo Bank, N.A., Sioux Falls, South Dakota, to establish a mobile branch to serve Dane County, Wisconsin. (Control Number 2005 ML 05 0102), 04/08/2005
685 Application to merge Atlantic Trust Company, National Association, Boston, Massachusetts, and Atlantic Trust Co., National Association, District of Columbia, into Atlantic Trust, National Association. (Control Number 2004 NE 02 054), 04/11/2005
686 Application by Citibank, National Association, New York, New York, for approval of an existing operating subsidiary to indirectly acquire a general partnership in a Cayman Island limited partnership whose sole activities are to hold and liquidate various foreign assets originally received by the Bank in satisfaction of debts previously contracted. (Control Number 2005 ML 08 0003), 04/14/2005
687 Application to combine Riggs Bank National Association, McLean, Virginia, with PNC Bank, National Association, Pittsburgh, Pennsylvania. (Control Numbers 2005 NE 02 0007; 2005 NE 02 0039; 2005 NE 08 0008; 2005 NE 09 0006; 2005 NE 12 0065 & 66; 2005 NE 12 0078 & 79), 04/25/2005

Charters with Standard Conditions

Letter No. Topic
688 Application to establish a new uninsured national trust bank with the title of Riggs National Trust Company. (Control Numbers 2005 NE 01 0001 & 2005 NE 08 0005), 03/28/2005
689 Application to establish a new national trust bank with the title of Wells Fargo Alaska Trust Company, National Association. (Control Number 2003 ML 01 0004), 11/14/2003

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2005-50, 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 April 15, 2005 through May 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.