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Interpretations and Actions: April 2008

Vol. 21, No. 4

Interpretive Letters

Letter No. Topic
1096 Letter states that if loans that were made before the borrower became an executive officer of the bank exceed the amounts permitted by Regulation O, they are grandfathered and do not violate Regulation O. However, no new loans may be made until loan balances are brought within Regulation O's limits. 03/20/2008
1097 Letter states that a national bank that wishes to acquire loans from a securitization trust, which is in process of winding down, also may acquire for a moment-in-time DPC real estate from the trust. Prior to such acquisition, the national bank must have an agreement in place to re-sell the DPC real estate immediately to a third party. 04/03/2008

Corporate Decisions

Letter No. Topic
2008-02 Application on behalf of First National Bank of the Gulf Coast to establish an operating subsidiary to conduct title insurance activities through a duly licensed agent within the state of Florida in accordance with the applicable laws and regulations governing this activity (Control Number 2007 SO 08 0033), 03/19/2008

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

Letter No. Topic
841 Application to establish a new national bank with the title of First National Bank of the Gulf Coast, Naples, Florida (Control Number 2007 SO 01 0027), 03/12/2008
842 Application by MB Financial Bank, N.A. to establish an operating subsidiary and to hold a limited equity investment in connection with its investment management activities (Control Number 2008 WO 08 0001), 03/13/2008
843 Application to establish a new national trust bank with the title of The Northern Trust Company of California, National Association, Chicago, Illinois (Control Number 2008 CE 01 001), 03/26/2008

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2008-41, 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 March 15, 2008 through April 14, 2008.

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 $200 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.