Interpretations and Actions: January 1997

Vol. 10, No. 1

PLEASE NOTE: Interpretive Letters and No Objection Letters reflect the views of the Comptroller's legal staff. Corporate Decisions and Decisions (CRA) are from the office of Bank Organization and Structure. The list of CRA Ratings is from the Communications Division. Copies of the documents not available electronically should be requested by email or by postal mail from the Office of the Comptroller of the Currency, Attn: Public Reference Room, Mailstop 1-5, Washington, D.C. 20219.

Please cite the letter number when reporting or summarizing documents from this package. This helps to process single requests in a more timely manner.

Interpretive Letters

Letter No.	Topic
757	Explains OCC's authority to permit converting state bank to retain non-conforming assets. (04/01/96)
758	Letter clarifies OCC's position with respect to a Bank's ownership and use of real estate property that it has owned since 1924. (04/05/96)
759	Whether a national bank may use a different credit scoring system for consumer loans it makes via the Internet than the one it uses for its other consumer loans. (05/01/96)
760	National bank may commit to purchase shares of affiliated mutual fund consisting solely of bank-eligible assets for same-day sale after the mutual fund would ordinarily close its books to new purchases. (11/14/96)
761	An unrestricted line of credit granted by a national bank to an executive officer that is secured by a first lien on the officer's residence is subject to the quantitative limitations set forth in section 22(g) of the Federal Reserve Act and its implementing regulation, the Federal Reserve Board's Regulation O. (11/21/96)
762	Letter addresses the application of the Community Reinvestment Act regulations to certain trade financing services offered by a national bank. (12/11/96)
763	Opinion addresses issues pertaining to the application of the Community Reinvestment Act to a bank's investment in a proposed umbrella partnership real estate investment trust that will engage in community development activities. (12/23/96)
764	Letter addresses issues pertaining to the treatment under the Community Reinvestment Act of banks' purchases of obligations of certain special purpose vehicles backed by a pool of whole loans consisting primarily of affordable housing mortgages. (12/23/96)
765	Letter states that loans to be used for church premises may be favorably considered under CRA provided the loans qualify as small business loans or community development loans. (12/24/96)
766	Letter addresses the interaction of OCC Trust Banking Circular 19 and the later enacted 12 U.S.C. 371c-1(b)(2). (01/06/97)

Corporate Decisions

Letter No.	Topic
97-01	Applications of The Anderson National Bank of Lawrenceburg, Lawrenceburg, Kentucky, to change the location of its main office to Lexington, Kentucky and to establish a branch office at the site of its former main office; (Control Numbers 96CE07038 & 96CE05141), (11/04/96).
97-02	Application to merge Chase Manhattan Bank USA, National Association, Jericho, New York, with and into Chase Manhattan Bank USA, National Association, Wilmington, Delaware; (Control Number 96NE020033), (11/26/96).
97-03	Applications of SunTrust Bank, South Georgia, N.A., Albany, Georgia, to change its main office location to Leesburg, Georgia and establish a branch at the former location of its main office; (Control Numbers 96SE070036 & 96 SE050155), (12/16/96).
97-04	Application to permit FMB Trust Company, National Association, McLean, Virginia, an operating subsidiary of First National Bank of Maryland, Baltimore, Maryland, to engage in fiduciary activities; (Control Numbers 96NE010018 & 96NE080046), (12/31/96).
97-05	Application to convert MetroBank, East Moline, Moline, Illinois to a national bank charter, retain a travel agency subsidiary subject to divestiture, and relocate to Davenport, Iowa; (Control Numbers 96CE01033, 96CE12187, & 96CE07033), (01/03/97).
97-06	Notification by Chase Manhattan Bank USA, NA, Wilmington, Delaware, of its intent to establish an operating subsidiary to reinsure mortgage insurance; (Control Number 96WO080009), (01/22/97).

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

Letter No.	Topic
226	Application by Mid Am, Inc., Bowling Green, Ohio to charter a new national trust bank with the title of Mid Am Private Trust, National Association. (Control Number 96CE010038), 12/11/96
227	Application by Dillard National Bank, Phoenix, Arizona to relocate its main office to Gilbert, Arizona. (Control Number 96WE070027), 12/20/96
228	Letter of intent from Associated Trust Company, Inc., Milwaukee, Wisconsin to convert to a national trust bank. (Control Number 96CE01040), 12/11/96
229	Letter of intent from Trust Company of Kentucky, Ashland, Kentucky to convert to a national trust bank. (Control Number 96CE01044), 12/17/96

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 97-9, 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, 1997 through January 14, 1997.

INTERPRETATIONS AND ACTIONS is published monthly by the Office of the Comptroller of the Currency. Subscriptions are available at a rate of $175 per year by writing to the Comptroller of the Currency, P.O. Box 73150, Chicago, IL 60673-7150. Prepayment is requested. Suggestions, comments or questions may be sent to Jacqueline J. England, Communications Division, Comptroller of the Currency, Washington, DC 20219.