Interpretations and Actions: November 2021

Vol. 34, No. 11

Interpretive Letters

Letter No.	Topic
1179	Letter clarifies that the cryptocurrency activities discussed in Interpretive Letters 1170, 1172 and 1174 are legally permissible for national banks and federal savings associations (banks), provided the bank can demonstrate that it has controls in place to conduct the activity in a safe and sound manner. It also clarifies Interpretive Letter 1176, which addresses the authority of the OCC to charter national banks within the scope of 12 U.S.C. § 27(a). (11/18/2021)

Letter No.

Topic

Letter clarifies that the cryptocurrency activities discussed in Interpretive Letters 1170, 1172 and 1174 are legally permissible for national banks and federal savings associations (banks), provided the bank can demonstrate that it has controls in place to conduct the activity in a safe and sound manner. It also clarifies Interpretive Letter 1176, which addresses the authority of the OCC to charter national banks within the scope of 12 U.S.C. § 27(a). (11/18/2021)

CRA Decisions

Letter No.	Topic
221	Application to merge Pacific Mercantile Bank, Costa Mesa, California with and into Banc of California, National Association, Santa Ana, California (Control Number: 2021-WE-Combination-321198, 09/30/2021)
222	Application by Bank of America, National Association, Charlotte, North Carolina, to establish a branch at 205 Smith Street, Brooklyn, New York (Control Number: 2021-LB-BranchNew 322494, 10/12/2021)
223	Application by Bank of America, National Association, Charlotte, North Carolina, to establish a branch at 5521 8^th Avenue, Brooklyn, New York (Control Number: 2021-LB-BranchNew 322499, 10/12/2021)
224	Application to merge Atlantic Capital Bank, National Association, Atlanta, Georgia, with and into South State Bank, National Association, Winter Haven, Florida (Control Number: 2021-SO-Combination-322891, 10/12/2021)
225	Application by Bank of America, National Association, Charlotte, North Carolina, to relocate its branch from 450 Carillon Parkway, Suite 220, St. Petersburg, Florida, to 200 Central Avenue, St. Petersburg, Florida (Control Number: 2021-LB-Relocation-322622, 10/15/2021)

Supervisory Condition Letters

Letter No.	Topic
2021-03	EH National Bank, Beverly Hills, California – Termination of Operating Agreement addressing strategic planning deficiencies, dated June 26, 2018. (11/02/2021)

Conditional Approvals

Letter No.	Topic
1274	Application of The First National Bank of Buhl, Mountain Iron, Minnesota, to change the composition of all, or substantially all, its assets through an expansion of operations (Control Number: 2021-CE-5.53-322817, 10/27/2021)

Community Reinvestment Act (CRA) Performance Evaluations

See OCC News Release 2021-113 announcing all CRA performance evaluations that became public from October 1, 2021 through October 31, 2021. 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 2021-118 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.