Interpretations and Actions: December 1998

Vol. 11, No. 12

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
846	Letter concludes that disbursal of loan proceeds by escrow agent affiliate of lender at non-branch office of the lender does not cause that office to be considered a branch. 06/29/98
847	A national bank may acquire a parcel of vacant real estate and lease such property to a school district pursuant to 12 CFR 7.1000(d), where the school district intends to construct a public school facility on the property. 10/28/98
848	Bank executive retirement plan may provide for installment payments to executive's beneficiary in event of executive's death, and bank may use life insurance to fund this obligation. 11/23/98
849	Letter opines that certain "Funds Transfer Agent Agreements" (FTAAs) would receive consideration as qualified investments during a during a bank's CRA evaluation as long as the FTAAs promote economic development by providing financial services that enable small-business marketers to grow, thus necessitating, for example, the hiring of additional employees, including low- and moderate-income individuals. (11/25/98)

Corporate Decisions

Letter No.	Topic
98-49	Application by First National Bank of Clovis, Clovis, New Mexico, to elect the corporate governance provisions of New Mexico law and complete a reverse stock split in accordance with those provisions. (Control Number 98WE12169), 11/02/98
98-50	Application to merge NationsBank of Tennessee, N.A., Nashville, Tennessee, into and under the charter and title of NationsBank, N.A., Charlotte, North Carolina. (Control Number 98ML020022), 11/04/98
98-51	Application by Community National Bank, Hudson, Massachusetts, to establish an operating subsidiary to provide employee benefit and compensation advice, and some incidental human resources consulting and career counseling, to small business customers. (Control Number 98NE080031), 11/30/98

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

Letter No.	Topic
292	Application by State Stores, Inc. to charter a national CEBA credit card bank with the title of "Granite National Bank," Bowling Green, Ohio. (Control Number 98CE010032 and 98CE120037), 03/20/98
293	Application by Mount Prospect National Bank, Mount Prospect, Illinois, to establish an operating subsidiary to make a noncontrolling investment in Northwest Suburban Mortgage, L.L.C. (Control Number 98CE080031), 11/24/98
294	Application by Belk Inc. to charter a national CEBA credit card bank with the title "Belk National Bank," Norcross, Georgia. (Control Number 98SE010022), 11/25/98

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 98-124, 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 November 15, 1998 through December 14, 1998.

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.