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Corporate Applications and Other Requests:

May 2006 Vol. 19, No. 5

IN THIS ISSUE:

Interpretive Letters

Letter No. Topic
1057 Letter confirms the appropriate capital treatment of a multipurpose loan commitment where the borrower has the option to utilize the commitment in one of several ways, including a standby letter of credit. WORD 06/14/2005
1058 Interagency letter addressing the risk-based capital treatment of structured second mortgages. WORD 04/20/2005
1059 Letter concludes that a national bank may engage in customer-driven, perfectly matched, cash-settled derivative transactions (such as swaps, options, forwards, caps, floors, collars and futures) where payments are based on prices of on (i) polypropylene: injection molding (copoly) (2,6); (ii) old corrugated cardboard #11 (OCC 11); and (iii) the Dow Jones AIG Commodity Index (DJ-AIGCI), provided the Bank's examiner-in-charge ("EIC") is satisfied that the Bank has adequate risk management and measurement systems and controls to conduct the activities on a safe and sound basis. WORD 04/13/2006
1060 Letter concludes that a national bank may engage in customer-driven coal derivative transactions that settle in cash or by transitory title transfer and that are hedged on a portfolio basis with derivative and spot transactions that settle in cash or by transitory title transfer, provided the bank's examiner-in-charge is satisfied that the bank has adequate risk management and measurement systems and controls to conduct the activities on a safe and sound basis. WORD 04/26/2006
1061 Letter states that loans secured by insured non-negotiable certificates of deposit issued by other institutions do not qualify for the exception in the legal lending limit for loans secured by certain other loans (12 C.F.R. 32.3(c)(3)(i)(B)) nor for the additional lending limit described in 12 C.F.R. 32.3(a) for loans secured by readily marketable collateral. WORD 04/28/2006
1062 Letter grants request of certain affiliated banks of a waiver from Part 12's requirement that bank officers and employees who make investment recommendations or decisions for customers must report their personal transactions in securities to the bank within ten business days after the end of the calendar quarter. WORD 04/24/2006

CRA Decisions

Letter No. Topic
134 Application by Rabobank, National Association, El Centro, California, to acquire Community Bank of Central California, Salinas, California (Control Number 2005 WE 02 0032), WORD 01/15/2006

Approvals with conditions enforceable under 12 U.S.C. 1818

Letter No. Topic
739 Application to convert Southwest Trust Company, Oklahoma City, Oklahoma to a national trust bank with the title of "Southwest Trust Company, National Association". (Control Number 2006 SO 01 00006), WORD 04/06/2006
740 Application by Grand Bank, N.A., Monmouth Junction, New Jersey, to issue subordinated debt. (Control Number 2006 NE 12 0109), WORD 02/21/2006
741 Application to establish a new national trust bank, which will engage solely in fiduciary activities, with the title of LaSalle National Trust Delaware," Wilmington, Delaware. (Control Number 2006 CE 01 002), WORD 04/21/2006

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2006-59, 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, 2006 through May 14, 2006.

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 FOIA-PA@occ.treas.gov. 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.