Interpretations and Actions: July 2020

Vol. 33, No. 7

Interpretive Letters

Letter No.	Topic
1168	Letter grants exemption from section 23A of the Federal Reserve Act and Regulation W, subject to conditions and limits (03/24/2020)
1169	Letter concludes that section 5A of the Home Owners’ Loan Act functions as a statutory exemption from the qualified thrift lender requirements described in section 10(m) of that Act, and a covered savings association operating under section 5A is not subject to the requirements of section 10(m)(3), including the provisions of section 10(m)(3)(B) (06/30/2020)
1170	Letter addresses the authority of a national bank to provide cryptocurrency custody services for customers (07/22/2020)

Conditional Approvals

Letter No.	Topic
1245	Notice of Change in Bank Control filed on behalf of Marth Phipps Maguire to acquire an indirect controlling interest in Bessemer Trust Company, N.A; Bessemer Trust Company of Delaware, N.A; and Bessemer Trust Company of California, N.A. (Control Numbers: 2020-NE-CBCA-314119, 34164 & 314165), 06/04/2020
1246	Application by Adyen N.V., Amsterdam, the Netherlands, to establish a Federal Branch in San Francisco, California, and a Loan Production Office in New York, New York (Control Number: 2010-NE-FBA-InitialEst-310409), 06/05/2020
1247	Application by Mid-Central Federal Savings Bank, Wadena, Minnesota, to convert to a national bank and residency waivers (Control Numbers: 2020-CE-Conversion-314328, 2020-CE-Waiver-314553), 06/16/2020
1248	Application submitted pursuant to 12 CFR 5.46(g)(1)(ii)(A) by Mission National Bank, San Francisco, California, for an increase in permanent capital (Control Number: 2020-WE Capital&Div-314746), 06/30/2020

Community Reinvestment Act (CRA) Performance Evaluations

See OCC News Release 2020-88 announcing all CRA performance evaluations that became public from June 1, 2020 through June 30, 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 2020-95 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.