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Corporate Applications:

March 2008

Vol. 21, No. 3

IN THIS ISSUE:

Interpretive Letters

Letter No. Topic
1093 Letter confirms that the subject national bank is authorized, by 12 U.S.C. 24(Seventh) and 12 C.F.R. part 37, to offer debt cancellation contracts (DCCs) to consumers through automobile dealers. The DCCs would be offered contingent on the bank's purchase of retail installment sales contracts that the dealers have originated to finance the consumers' automobile purchases. 10/29/2007
1094 Letter confirms that the subject national bank is authorized pursuant to 12 U.S.C. § 24(Seventh) and 12 C.F.R. § 7.4002 to establish and charge a fee to a non-accountholder customer for the service of cashing an official check. 02/27/2008
1095 Letter addresses two issues in connection with a national bank's sales of its debt cancellation contracts (DCCs): (1) If a bank offers a DCC on a closed-end loan that is repayable in 5 years, and the DCC provides protection for the full 5-year loan term, can the bank collect the full cost of the DCC in monthly periodic payments over the first year of the loan; and (2) Can an automobile dealer sell a national bank's DCC, as the bank's agent, in connection with the dealer's automobile retail installment sales contract that the dealer will assign to the bank, and does the OCC's DCC regulation apply to this transaction? 02/27/2008

Community Development Investment Letters

Letter No. Topic
2007-1 Investment in the renovation and resale of single family properties - A national bank through its wholly owned subsidiary community development corporation may invest, using a combination of debt and equity, in the acquisition and renovation of single family homes located in low- or moderate-income communities, which are then resold. 08/17/2007
2007-2 Investment in the construction and sale of single family properties - A national bank through its subsidiary community development corporation may invest, using a combination of debt and equity, in the construction of single family homes located in low- or moderate-income communities, which are then sold to low and moderate income individuals. 10/11/2007

CRA Decisions

Letter No. Topic
141 Application by BLC Bank, National Association, Strasburg, Pennsylvania to merge with and into PNC Bank, National Association, Pittsburgh, Pennsylvania (Control Number 2007 NE 02 022), 02/07/2008

Approvals with conditions enforceable under 12 U.S.C. 1818

Letter No. Topic
837 Application of First National Bank of Colorado, Boulder, Colorado, to change the composition of all, or substantially all, of its assets by sale to First National Bank, Ft. Collins, Colorado (Control Number 2007 WE 12 0241), 01/29/2008
838 Application by ICICI Bank Limited, Mumbai, India, to establish a federal branch in New York, New York (Control Number 2004 IB 10 0003), 02/25/2008
839 Application by Barclays Global Investors, National Association, San Francisco, California, for a reduction in permanent capital (Control Number 2008 WE 12 0048), 02/27/2008
840 Application to merge First National Bank of the Mid-Cities, Bedford, Texas into First National Bank and Trust Company of Weatherford, Weatherford, Texas (Control Number 2006 SO 02 0027), 02/27/2008

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 2008-31, announcing the availability of enforcement actions. Copies of the final actions are available by writing to the OCC, Public Information Room, Mail Stop 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 February 15, 2008 through March 14, 2008.

PLEASE NOTE: Interpretive Letters and No-Objection Letters reflect the views of the Comptroller's legal staff. Corporate Decisions, CRA Decisions and Conditional Approvals are from the office of Licensing. The Community Development Investment Letters are from the office of Community Affairs. The list of CRA Ratings is from the Communications Division. For copies of the CRA evaluations, you may either contact the bank directly, or you may write to the Office of the Comptroller of the Currency (OCC) in any of three ways: by mail to the OCC, Attn: Public Information Room, Mail Stop 1-5, Washington, D.C. 20219; by fax to (202) 874-4448; or by e-mail to FOIA-PA@occ.treas.gov. You may also write to the OCC for copies of enforcement actions and charters with standard conditions.

Members of the news media are encouraged to cite the letter number when reporting or summarizing documents from this package. This helps us to process single requests based upon your citation in a timelier manner.

The Office of the Comptroller of the Currency publishes INTERPRETATIONS AND ACTIONS monthly. Subscriptions are available at a rate of $200 per year by writing to the Comptroller of the Currency, ATTN: Accounts Receivable, Mail Stop 4-8, 250 E Street, S.W., Washington, DC 20219. Prepayment is requested. Suggestions, comments or questions may be sent to Jacqueline J. England, Comptroller of the Currency, Communications Division, Mail Stop 3-2, Washington, DC 20219.