Interpretations and Actions: January 2000

Vol. 13, No. 1

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; Fax: (202) 874-4448.

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
875	Key Bank USA, National Association may lawfully acquire and hold a non-controlling, minority interest in Econex LLC, a limited liability company that will provide certain Internet-related services to merchants, and that it is legally permissible for Key Merchant Services, LLC, a limited liability company in which the Bank holds a non-controlling, minority interest, to expand its activities to include the Internet- related services to merchants. 10/31/99
876	No-objection letter to proposal by a federally licensed branch to act as agent in brokering Australian and New Zealand government and corporate securities purchased by its parent bank and resold pursuant to SEC Rule 144A. 12/08/99
877	Letter confirms that a trust company may sell pursuant to section 92 from a trust office located in a place with a population of 5,000 or few inhabitants if the trust office performs "core fiduciary functions" at its office in the "place." 12/13/99
878	Letter confirms that a national bank subsidiary may hold various insurance company products and investment un funds in order to hedge, on a dollar-for-dollar basis, the subsidiary's obligations to make payments to employees under nonqualified deferred compensation plans. 12/22/99

Corporate Decisions

Letter No.	Topic
99-44	Application by National Penn Bank, Boyertown, Pennsylvania, to expand the activities of Link Financial Services, Inc. to engage in the sale of additional lines of insurance as agent, including long-term care, property and casualty insurance. (Control Number 1999 NE 08 0036), 09/10/99
99-45	Application by the First National Bank of Sharp County, Ash Flat, Arkansas, to establish a messenger service branch. (Control Number 1999 SW 05 0187), 11/04/99
99-46	Application to merge LaSalle Bank, F.S.B., Chicago, Illinois, with and into LaSalle Bank National Association, Chicago, Illinois. (Control Number 1999 CE 02 042), 12/02/99
99-47	Application by SOFTBANK Finance America Corporation, Wilmington, Delaware, to acquire CompuBank, N.A., Houston, Texas. (Control Number 1999 SW 11 0002), 12/07/99
99-48	Application by Wheeling National Bank, St. Clairsville, Ohio, to purchase certain assets and to assume certain liabilities of the Barnesville branch of Sky Bank, Salineville, Ohio. (Control Number 1999 NE 02 0039), 12/20/99
99-49	Application for the Havana National Bank, Havana, Illinois, to purchase certain assets and assume certain liabilities of the Havana and Lewistown branch offices of Associated Bank Illinois, National Association, Rockford, Illinois. (Control Number 1999 CE 02 0045), 12/22/99
99-50	Application by the First National Bank of Omaha, Omaha, Nebraska to expand the activities of SPC, Inc. to include referring its merchant customers to a third party that would provide Website development services for these merchants and processing purchases made over the Internet with debit and credit cards. (Control Number 1999 MW 08 0031), 12/23/99
99-51	Application by UMB Bank, National Association, Kansas City, Missouri, to establish an operating subsidiary, to be known as eScout.com LLC, which would engage in research and development activities in connection with the anticipated transfer of the Bank's current Internet Website to the LLC. (Control Number 1999 MW 08 032), 12/23/99

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

Letter No.	Topic
342	Application by First National Bank of Hampton, Hampton, Iowa, to elect the corporate governance provisions of Iowa law and complete a reverse stock split in accordance with those provisions. (Control Number 1999 MW 12 163), 12/03/99
343	Application by First Suburban National Bank, Maywood, Illinois, to establish a branch in Skokie, Cook County, Illinois. (Control Number 1999 CE 05 219), 12/13/99
344	Application by The First National Bank of Hope, Hope, Kansas, to elect the corporate governance provisions of Kansas law and complete a reverse stock split in accordance with those provisions. (Control Number 1999 MW 12 154), 12/16/99
345	Application to convert Idaho Trust Company, Coeur d'Alene, Idaho, to a national charter with the title of "Wealthbank, National Association." (Control Number 1999 WE 01 0013), 12/21/99
347	Application to charter Aerobank.com, National Association, San Jose, California. (Control Number 1999 WE 01 0007), 01/29/2000

Each of the following charter application(s) were approved with a standard condition enforceable under 12 U.S.C. 1818 that requires the bank, during the first three years of its operation, to provide notice to the OCC at least 30 days in advance of any significant deviations or changes from its proposed operating plan. Copies of the decision(s) are available by writing to the Office of the Comptroller of the Currency, Attn: Public Reference Room, Mailstop 1-5, Washington, D.C. 20219; Fax: (202) 874-4448; Email: FOIA-PA@occ.treas.gov; or the OCC Web: http://www.occ.gov. When ordering please specify the appropriate document number.

Letter No.	Topic
346	Baytree National Bank & Trust Company, (Control Number 1999 CE 01 0010), 12/28/99

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2000-03 , 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 December 15, 1999 through January 14, 2000.

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, Mailstop 3-2, Comptroller of the Currency, Washington, DC 20219.