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Interpretations and Actions: September 2007

Vol. 20, No. 9

Interpretive Letters

Letter No. Topic
1086 Letter confirms authority of the Bank under 12 USC 24(Seventh) and in accordance with 12 CFR Part 1 to purchase and hold for its own account shares of fixed-rate, cumulative preferred securities. The securities have characteristics typically associated with debt instruments, rather than common stock. Although the securities are perpetual, they are callable at the option of the Issuer. The conclusion in the Letter is subject to the condition that the Bank will not exercise the right granted to holders of the securities to convert them into common stock of the issuer so long as the securities are held by the Bank or any subsidiary. 08/23/2007
1087 The letter states that the deferred share units of the Bank's holding company, described therein, effectively represent an equity investment for the purpose of directors' qualifying shares, meeting the requirement of 12 U.S.C. 72 that directors have a financial stake to assure the financial success of the Bank, and qualify as an "equivalent interest" in the Bank's parent holding company. 09/05/2007

Corporate Decisions

Letter No. Topic
2007-07 Proposal to merge the Citizens Bank of Massachusetts, Boston, MA; Citizens Bank of Connecticut, New London, CT; Citizens Bank of Rhode Island, Providence, RI; Citizens Bank of New Hampshire, Manchester, NH; Citizens Bank, Wilmington, DE; Charter One Bank, National Association, Cleveland, OH; RBS National Bank, Bridgeport, CT; and CCO Mortgage Corp., Glen Allen, VA into Citizens Bank, National Association, Albany, NY, under the charter of the latter and with the title of "RBS Citizens, National Association," and its main office in Providence, Rhode (Control Numbers 2007 NE 02 012 - 013 and 2007 NE 12 0147), 08/02/2007

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

Letter No. Topic
813 Change in Bank Control Act Notice in connection with the proposed acquisition of Premier Commercial Bank Arizona, National Association, Mesa, Arizona, by Steven J. Ellsworth and Kevin W. Stevenson (Control Number 2007 WE 11 0002), 08/01/2007
814 Premier Commercial Bank Arizona, National Association, Mesa, Arizona, notice of significant deviation from business plan and request to appoint certain new directors and executive officers 08/01/2007
815 Application of The Bankers Bank, Atlanta, Georgia, to convert to a national banking association with the title of "The Bankers Bank, National Association" (Control Number 2007 SO 01 0007), 08/07/2007
816 Application by Huntington National Bank, Columbus, Ohio, to acquire, through merger, Sky Bank, Salineville, Ohio and Sky Trust, National Association, Pepper Pike, Ohio (Control Number 2007 CE 02 007), 08/16/2007
817 Application to establish Founders Bank & Trust, National Association, Leesburg, Virginia (Control Number 2007 NE 01 0001), 08/24/2007
818 Application to establish a new national bank with the title of " Touchstone National Bank, Duluth, Georgia (Control Number 2007 SO 01 0016), 08/28/2007

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2007-96, 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 August 15, 2007 through September 14, 2007.

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.