Interpretations and Actions: October 2019

Vol. 32, No. 10

Interpretive Letters

Letter No.	Topic
1166 (PDF)	Letter concludes that a national bank’s proposal to streamline the filing of suspicious activity reports by automating the process for identifying and reporting potential structuring activity is consistent with 12 CFR 21.11 and 12 CFR21.21 (09/27/2019)

Supervisory Condition Letters

Letter No.	Topic
2019-01 (PDF)	Cadence Bank, N.A., Houston, Texas – Termination of supervisory condition letter dated June 9, 2016 (02/21/2019)

Corporate Decisions

Letter No.	Topic
2019-01 (PDF)	Application by Fifth Third Bank, Cincinnati, Ohio, to convert to a national banking association and exercise fiduciary power (Control Numbers: 2019-CE-Conversion-309147 & 2019-CE-Fiduciary-309595), 09/10/2019

Conditional Approvals

Letter No.	Topic
1228 (PDF)	Application by First Colorado National Bank, Paonia, Colorado, to sell and exit its Small Business Association line of business through a loan and asset purchase agreement with First Internet Bank of Indiana (Control Number: 2019-WE-5.53-309261), 09/03/2019
1229 (PDF)	Application to merge River Cities Bank, Wisconsin Rapids, Wisconsin, into Time Federal Savings Bank, Medford, Wisconsin, and the application for the retention of two operating subsidiaries (Control Numbers: 2019 CE-Combination-309756 and 2019-CE-Sub&Equities-310457), 09/13/2019
1230 (PDF)	Applications of South Central Bank, National Association, Chicago, Illinois, to change the composition of all or substantially all, its assets by sale; establish a wholly-owned operating subsidiary, SCBNA,L LLC; merge the Bank with and into SCBNA, LLC; and make a liquidating dividend (Control Numbers: 2019 CE-215a3-309947, 2019-CE-5.53-309948, & 2019-CE-Subs&Equities-310402), 09/17/2019
1231 (PDF)	Applications by First Citizens Bank of Polson, NA, Polson, Montana, for increases in permanent capital totaling $437,167 for 2018 and $263,924 through June 30, 2019 (Control Number: 2019 NE-Charter-305362), 08/19/2019

Community Reinvestment Act (CRA) Performance Evaluations

See OCC News Release 2019-113 announcing all CRA performance evaluations that became public from September 1, 2019 through September 30, 2019. A search of all public CRA evaluations can be done at http://apps.occ.gov/crasearch/default.aspx.

Final Enforcement Actions

See OCC News Release 2019-121 announcing the availability of enforcement actions. All final enforcement actions are searchable at http://apps.occ.gov/EnforcementActions/.

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.

If you are unable retrieve the CRA evaluations or enforcement actions online, you can submit a request to obtain copies at the OCC’s online FOIA site, https://foia-pal.occ.gov/palMain.aspx. 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 7^th Street, SW, Suite 3E-218, Washington, DC 20219.