AL 97-5
   
Subject:  Treasury's Large Position Recordkeeping and Reporting       Rules

TO:  Chief Executive Officers of All National Banks, Department
     and Division Heads, and all Examining Personnel


At the request of the U.S. Department of the Treasury, the OCC is
forwarding the attached document regarding Treasury's large
position rules (17 CFR 420) which became effective March 31,
1997.  Treasury prepared this question and answer document to
assist entities, including banks, in determining if they or their
affiliates are subject to the recordkeeping and reporting
requirements.  Since the rules apply to a wide variety of bank
and affiliate activities, including portfolio investments,
broker-dealer, foreign affiliates, and fiduciary activities, each
bank should review the Qs and As to determine if it could be
subject to the recordkeeping and/or reporting requirements.  In
general, an entity becomes subject to the recordkeeping
requirements when  it controls a position in a recently-issued
Treasury security of at least $2 billion.  An entity becomes
subject to the reporting requirements only when its position
equals or exceeds Treasury's publicly announced threshold
requesting large position reports.  Treasury has stated that this
threshold will not fall below $2 billion. 

Periodic updates to the Qs and As and the large position rules
can be obtained from the Bureau of Public Debt's Web site
(www.publicdebt.treas.gov) or by calling the Bureau of the Public
Debt, Government Securities Regulations Staff at (202-219-3632). 
Examiners should call the Treasury and Market Risk Division on
(202-874-5670) or Fiduciary Activities (202-874-5419) to discuss
issues relating to the examination process.


                                      
G. Scott Calhoun
Deputy Comptroller for Risk Evaluation and Capital Markets


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