Interpretations and Actions: June 2020

Vol. 33, No. 6

Interpretive Letters

Letter No.	Topic
1167 (PDF)	Letter concludes that subject to the limits established by 12 U.S.C. § 92a and 12 C.F.R. part 9, a national bank may exercise fiduciary powers in any state without obtaining a state money transmitter license (05/20/2020)

CRA Decisions

Letter No.	Topic
202 (PDF)	Application to merge Steuben Trust Company, Hornell, New York, with and into Community Bank, National Association, Canton, New York (Control Number: 2020-NE-Combination-311909), 05/11/2020

Conditional Approvals

Letter No.	Topic
1243 (PDF)	Rebuttal of Control of BlackRock Institutional Trust Company, National Association, San Francisco, California, filed by The Vanguard Group, Inc., Valley Forge, Pennsylvania (Control Number: 2020-NE-CBCA-314526), 05/15/2020
1244 (PDF)	Applications by Neighborhood National Bank, Mora, Minnesota, to change the composition of all, or substantially all, of its assets by sale and then merge with and into Neighborhood Holdings, Inc., Mora, Minnesota (Control Numbers: 2020-CE-5.53-314051 & 215a3-314052), 05/19/2020

Community Reinvestment Act (CRA) Performance Evaluations

See OCC News Release 2020-74 announcing all CRA performance evaluations that became public from April 1, 2020 through April 30, 2020. A search of all public CRA evaluations can be done at http://apps.occ.gov/crasearch/default.aspx.

Final Enforcement Actions

There were no enforcement actions published this month. 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.