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Interpretations and Actions: November 2015

Vol. 28, No. 11

Interpretive Letters

Letter No. Topic
1155 (PDF) Letter concludes that the Ohio Financial Institutions Tax (FIT) is inconsistent with 12 USC 548 and, therefore, is not authorized under federal law.  09/17/2015

Supervisory Condition Letters

Letter No. Topic
2015-09 (PDF) Capital Bank, N.A., Coral Gables, Florida – Conditional Approval of Termination of Operating Agreement  08/27/2015
2015-10 (PDF) NBH Bank, N.A., Kansas City, Missouri – Termination of Operating Agreement  10/14/2015

CRA Decisions

Letter No. Topic
170 (PDF) Application by Sunshine Bank, Plant City, Florida, for the purchase of certain assets and assumption of certain liabilities of First Federal Bank of Florida, Lake City, Florida  (Control Number:  2015-SO-144655), 10/28/2015

Conditional Approvals

Letter No. Topic
1136 (PDF) Applications for voluntary dissolution, transfer of assets, and capital distribution filed on behalf of Boulevard Bank, Des Peres, Missouri  (Control Numbers:  2015-HQ-144173, 144174, & 144175), 10/06/2015
1137 (PDF) Applications to merge Stifel Trust Company, NA into Stifel Interim, NA and merge Stifel Interim, NA into 1919 Investment Counsel and Trust Company, NA, with the resulting institution’s main office located in St. Louis, Missouri and title of Stifel Trust Company, NA and applications by 1919 Investment Counsel and Trust Company, NA to reduce permanent capital.  (Control Numbers:  2015-NE-Combination-142074; 2015-NE-Combination-142074; 2015-Cap&Div-142086; 2015-Cap&Div-144902, & 2015-Cap&Div-144903), 10/07/2015
1138 (PDF) Application for substantial asset change by CertusBank, N.A., Greenville, South Carolina, and application for the merger of CertusBank, N.A., with and into CBSUB, Inc., Wilmington, Delaware  (Control Numbers:  2015-HQ-145108 & 2015-HQ-145171), 10/08/2015
1139 (PDF) Application by Anchor Bank, National Association, Saint Paul, Minnesota, to include an issuance of subordinated debt in its Tier 2 capital  (Control Numbers:  2015-CE-Capital&Div-144991), 10/09/2015
1140 (PDF) Application by Royal Bank of Canada, Montreal, Canada, to establish a limited Federal branch with fiduciary powers at 30 Hudson Street, Jersey City, New Jersey  (Control Numbers:  2014-NE-FBA-AddEst-139834 & 2014-NE-FBA-Fiduciary-145047), 10/09/2015

Community Reinvestment Act (CRA) Performance Evaluations

See OCC News Release 2015-148 announcing all CRA performance evaluations that became public from October 1, 2015, through October 31, 2015. A search of all public CRA evaluations can be done at

Final Enforcement Actions

See OCC News Release 2015-151 announcing the availability of enforcement actions. All final enforcement actions are searchable at

PLEASE NOTE: Interpretive Letters and No-Objection Letters reflect the views of the Office of the Comptroller of the Currency’s (OCC) legal staff. Corporate Decisions, CRA Decisions and Conditional Approvals are from the office of Licensing Activities. The Community Development Investment Letters are from the office of Community Affairs. The Supervisory Conditions Letters are from the Special Supervision Division. The list of CRA Ratings is from the Communications Division.

You can obtain copies of CRA evaluations or enforcement actions by writing to the Freedom of Information Act Officer, Disclosure Services, Communications Division, OCC, 400 7th Street, SW, Suite 3E-218, Washington, DC 20219. You may also submit a request electronically at the OCC’s online FOIA site, Please provide all identifying information when requesting documents. You may also contact the bank directly for copies of the CRA evaluations.

The OCC publishes INTERPRETATIONS AND ACTIONS monthly. Send suggestions, comments or questions to Jacqueline England, Disclosure Services, Communications Division, OCC, 400 7th Street, SW, Suite 3E-218, Washington, DC 20219.