Interpretations and Actions: August 2020

Vol. 33, No. 8

Interpretive Letters

Letter No.	Topic
1171	Letter applies the framework established in OCC Interpretive Letter 822 and concludes that the Bank may charge interest on credit cards consistent with [State X] law because (1) the non-ministerial function of loan approval for credit cards occurs in [State X] and (2) the Bank’s credit card lending has a clear nexus with [State X]. (06/01/2020)

Conditional Approvals

Letter No.	Topic
1249	Application submitted on behalf of Agility Bank, National Association, Houston, Texas (Charter No. 25225), to establish a new national bank (Control Number: 2020-SO-Charter-314136), 07/29/2020

Community Reinvestment Act (CRA) Performance Evaluations

See OCC News Release 2020-103 announcing all CRA performance evaluations that became public from July 1, 2020 through July 31, 2020. 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 2020-107 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.