Interpretations and Actions: October 1997

Vol. 10, No. 10

PLEASE NOTE: Interpretive Letters and No Objection Letters reflect the views of the Comptroller's legal staff. Corporate Decisions and Decisions (CRA) are from the office of Bank Organization and Structure. The list of CRA Ratings is from the Communications Division. For copies of the evaluation, you should contact the bank directly or the Office of the Comptroller of the Currency, Attn: Public Reference Room, Mailstop 1-5, Washington, D.C. 20219.

Members of the news media are encouraged to cite the letter number when reporting or summarizing documents from this package. This helps to process single requests in a more timely manner.

Interpretive Letters

Letter No.	Topic
800	Interagency CRA interpretive letter addressing three issues in connection with financial institutions' investments in pooled national community development funds. The issues are: (1) Whether the CRA regulations treat an institution's investment differently according to whether the institution invests directly in a project or indirectly, such as through a national fund; (2) When and how examiners consider such an investment in a national fund by an institution; and (3) How the CRA regulations define "region" for purposes of evaluating a wholesale or limited purpose institution's performance under the community development test. (09/11/97)
801	Interagency CRA staff interpretive letter addressing two issues: (1) Whether the timing of payments of a qualified investment will affect the amount of consideration received; and (2) How examiners will evaluate an institution's qualified investments in a partnership with nationwide investments. (08/11/97)
802	Letter states that a financial institution's activities in connection with a program offering a financial services education curriculum for high school students would receive favorable CRA consideration if the students participating in the course were low- and moderate- income. (09/17/97)
803	Letter opines on whether certain fees are interest under 12 U.S.C. 85 and 12 CFR 7.4001(a). (9/07/97)

Corporate Decisions

Letter No.	Topic
97-85	Applications by Wells Fargo Bank, N.A. to establish branches at various locations; (Control Numbers 97ML050372 & 97ML050377 thru 0393), (08/22/97).
97-86	Applications to merge Matewan National Bank/Kentucky, Pikeville, Kentucky with and into Matewan National Bank, Matewan, West Virginia, and to establish five branches in Virginia; (Control Numbers 97SE020041 & 97SE050170 thru 0174), (09/12/97).
97-87	Application by Vermont National Bank, Brattleboro, Vermont, to combine with its affiliate, Vermont Federal Bank, Federal Savings Bank; (Control Numbers 97NE020031 & 0032, 97NE010015, & 97NE050132), (09/13/97).
97-88	Application to merge fifteen Michigan state bank affiliates with and into The Huntington National Bank, Columbus, Ohio; (Control Number 97CE020053), (09/15/97).
97-89	Notification by Norwest Bank Minnesota, N.A., Minneapolis, Minnesota, of its intent to establish an operating subsidiary to reinsure mortgage insurance; (Control Number 97MW08022), (09/26/97).
97-90	Applications to establish Stephenson National Bank (SNB) and to merge SNB with and into The Stephenson National Bank and Trust, Marinette, Wisconsin, under the charter of the latter; (Control Numbers 97CE010030 & 97CE020067), (10/03/97).

Approvals with Conditions Enforceable under 12 U.S.C. 1818

Letter No.	Topic
255	Application of First National Bank of Omaha, Omaha, NE, for an existing operating subsidiary to purchase a non-controlling minority interest in Data Processors International, Inc., a merchant processing corporation. (Control Number 97MW080036), 09/25/97
256	Application to charter State Street Global Advisors, National Association, Naples, Florida, as an operating subsidiary of State Street Bank and Trust Company, Boston, Massachusetts. (Control Number 97NE01018), 09/30/97
257	Application by IBAA Bancard, Inc. to charter a national CEBA credit card bank with the title of "TCM Bank, National Association." (Control Number 97SE0101128),09/30/97

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 97-96, announcing the availability of enforcement actions. Copies of the final actions are available by writing to the OCC, Public Reference Room, Mailstop 1-5, Washington, D.C. 20219. When ordering, specify the appropriate Enforcement Action Number.

Community Reinvestment Act (CRA) Performance Evaluations

Enclosed is a list of CRA performance evaluations that became public during the period of September 15, 1997 through October 14, 1997.

INTERPRETATIONS AND ACTIONS is published monthly by the Office of the Comptroller of the Currency. Subscriptions are available at a rate of $175 per year by writing to the Comptroller of the Currency, P.O. Box 70004, Chicago, IL 60673-0004. Prepayment is requested. Suggestions, comments or questions may be sent to Jacqueline J. England, Communications Division, Comptroller of the Currency, Washington, DC 20219.