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Corporate Applications and Other Requests:

January 2004

Vol. 17, No. 1


Interpretive Letters

Letter No. Topic
978 Letter denies a request for a Suspicious Activity Report (SAR) for use in private litigation because the public policy against disclosure, as reflected in Congressional enactments, agency regulations and recent court decisions, is very strong. WORD 12/04/2003
979 Letter interprets the common source of repayment test in 12 C.F.R. 32.5(c)(1) and finds that, on the specific facts presented, the test does not result in the combination of loans to members of the Indian Community with loans to other members or with a loan to the Community. WORD 12/18/2003
980 Letter concludes that the installation of UPS drop boxes at non-branch offices of a bank will not cause those offices to be considered branches under 12 USC 36 because they are owned by an independent third party and can be used by the general public for nonbanking transactions. WORD 12/24/2003

CRA Decisions

Letter No. Topic
119 Merger of Bank One Delta Trust Company, National Association (In Organization), Bank One Epsilon Trust Company, National Association (In Organization), and Bank One Zeta Trust Company, National Association (In Organization) into J.P. Morgan Trust Company, National Association, Los Angeles, California. (Control Number 2003 NE 02 033), WORD 10/24/2003
120 Application by Sun National Bank, Vineland, New Jersey, to purchase certain assets and acquire certain liabilities of eight New Jersey branches of New York Community Bank, Westbury, New York. (Control Number 2003 NE 02 0036), WORD 11/04/2003
121 Merger of United Trust Bank, Bridgewater, New Jersey into PNC Bank, National Association, Pittsburgh, Pennsylvania. (Control Numbers 2003 NE 02 040 & 2003 NE 05 152), WORD 12/03/2003

Corporate Decisions

Letter No. Topic
2004-1 Application to relocate the main office of First Consumers National Bank from 9300 S. W. Gemini Drive, Beaverton, Oregon to 4800 S. Meadows Road, Lake Oswego, Oregon. (Control Number 2003 WE 07 0032), WORD 11/21/2003

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

Letter No. Topic
615 Application to charter Commerce National Bank, Fullerton, California. (Control Number 2002 WE 01 0010), WORD 12/11/2003
616 Application by Mission National Bank, San Francisco, California to purchase certain assets and assume the liabilities of the Mission Street branch, san Francisco, California of Pan American Bank, FSB, Burlingame, California. (Control Number 2003 WE 02 0012), WORD 12/16/2003
617 Plan of F.N.B. Corporation to divide into two public companies in Pennsylvania and Florida:
Affiliated merger of First National Trust Company, Hermitage, Pennsylvania into First National Bank of Pennsylvania, Hermitage, Pennsylvania. (Control Number 2003 SD 02 0002), WORD 12/22/2003
Merger (215a-3) of First National Investment Services Company into First National Bank of Pennsylvania. (Control Number 2003 SW 12 0203), WORD 12/22/2003
Trust bank charter for First National Trust Company, Hermitage, Pennsylvania. (Control Number 2003 SD 01 0001), WORD 12/22/2003
Trust bank charter for First National Wealth Management Company, Naples, Florida. (Control Number 2003 SD 01 0002), WORD 12/22/2003
Capital application for alteration of terms of trust preferred stock issuance of First National Bank of Pennsylvania. (Control Number 2002 SD 12 0008), WORD 12/22/2003
Non-cash dividend request for First National Bank of Pennsylvania, Hermitage, Pennsylvania. (Control Number 2003 SD 12 0098), WORD 12/22/2003

Charters with standard condition

Each of the following charter application(s) were approved with a standard condition enforceable under 12 U.S.C. 1818 that requires the bank to provide notice and obtain OCC's non-objection in advance of any significant deviations or changes from its business plan or operations.

Letter No.Topic
618 Application to charter First National Bank of Decatur County, Bainbridge, Georgia. (Control Number 2003 SW 01 0004), WORD 11/06/2003

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2004-6, announcing the availability of enforcement actions. Copies of the final actions are available by writing to the OCC, Public Reference Room, Mailstop 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 December 15, 2003 through January 14, 2004.

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 Licensing department. 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 more timely 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, Mailstop 4-8, 250 E Street, S.W., Washington, DC 20219. Prepayment is requested. Suggestions, comments or questions may be sent to Jacqueline J. England, Communications Division, Comptroller of the Currency, Mail Stop 3-2, Washington, DC 20219.