Corporate Applications:

Vol. 12, No. 8

IN THIS ISSUE:

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
863	Letter concludes that the creditworthiness of individual borrowers is not determinative in applying the loan aggregation rules in 12 CFR 32.5(c)(3) to ascertain whether borrowers are engaged in a common enterprise to acquire more that 50 % of a business enterprise. 07/22/99
864	Letter confirms that bank insurance agency, appropriately located in a "place of 5,000," may solicit and sell insurance in the manner permissible for insurance agencies generally in the states of Illinois and Michigan and as authorized by the agency's insurance licenses in. 05/19/99
865	State bank seeks confirmation that it may pool cash collateral held pursuant to securities lending agreements into common trust funds. 05/26/99

Corporate Decisions

Letter No.	Topic
99-17	Application by Sapelo National Bank, Darien, Georgia, to purchase and assume the Brunswick, Georgia branch of Republic Bank, Federal Savings Bank, St. Petersburg, Florida. (Control Number 99 SE 02 0028), 03/26/99
99-18	Application to merge Navigation Bank, Houston, Texas, into SouthTrust Bank, National Association, Birmingham, Alabama, under the charter and title of SouthTrust Bank, National Association. (Control Number 99 SE 02 0033), 07/07/99
99-19	Application of First Bank and Trust, Groves, Texas, to merge with and into SouthTrust Bank, National Association, Birmingham, Alabama. (Control Number 99 SE 02 0038), 07/28/99
99-20	Applications by InterBank, National Association, Elk City, Oklahoma; Bank of Oklahoma, National Association, Tulsa, Oklahoma; First National Bank and Trust Company of Weatherford, Weatherford, Oklahoma; and First Fidelity Bank National Association, Oklahoma City, Oklahoma, to establish branches based on 12 USC 36 and the branching authority of savings and loan associations chartered by the state of Oklahoma. (Control Numbers 99 SW 05 0106, 107, 111, 122, & 124), 07/28/99
99-21	Application of First National Bank, Orangeburg, South Carolina, to purchase certain assets and assume certain liabilities (The Hardeeville and Ridgeland, South Carolina branches) of Carolina First Bank, Greenville, South Carolina, under the title and charter of First National Bank, Orangeburg, South Carolina. (Control Number 99 SE 02 0039), 07/29/99
99-22	Application by Popular Inc. to charter a national bank with the title "Banco Popular, National Association," Orlando, Florida and the application for Banco Popular, National Association to purchase certain assets and assume certain liabilities of the Culebra branch of Banco Popular de Puerto Rico, San Juan, Puerto Rico. (Control Numbers 99 NE 01 0005 & 99 NE 02 0007), 07/30/99
99-23	Application to purchase certain assets and assume the liabilities of the Pratt branch of Intrust Bank, National Association, Wichita, Kansas, by First National Bank in Pratt, Pratt, Kansas, under the charter and title of First National Bank in Pratt. (Control Number 99 MW 02 0023), 08/11/99
99-24	Applications of KeyCorp and KeyBank, National Association, Cleveland, Ohio to charter an interim national bank, for the interim bank to acquire certain branches , including the purchase of certain assets and the assumption of certain liabilities associated with the branches, from KeyBank and for approval to merge the interim bank with and into KeyBank. (Control Numbers 99 CE 02 0024 & 025, 99 CE 02 0107 & 108), 08/11/99

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

Letter No.	Topic
317	Application of First Tennessee Bank, N.A., Memphis, Tennessee, to participate in a joint venture real estate tax reporting and management services. (Control Number 99 SE 08 021), 07/19/99
318	Application of National Bank of Commerce of Birmingham, N.A., Birmingham, Alabama, to participate through an operating subsidiary in a joint venture conducting residential mortgage lending services. (Control Number 99 SE 08 0011), 07/21/99
319	Request by Michigan National Bank to acquire ownership interests in Checkfree Corporation from Integrion Financial Network, L.L.C. (Control Number 99 WO 08 0013), 07/26/99
320	Request by National Bank of Commerce of Mississippi, Starkville, Mississippi, to establish an operating subsidiary for the purpose of acquiring two insurance agencies. (Control Number 99 SE 08 0025), 07/28/99
321	Application of Bank One, National Association, Columbus, Ohio, to acquire a noncontrolling interest in a limited liability company through an existing operating subsidiary. (Control Number 99 ML 08 008), 07/28/99
322	Request by First Union National Bank, Charlotte, North Carolina, to acquire through an existing operating subsidiary a 50% voting interest in a limited liability company engaged in title insurance agency and loan-related activities. (Control Number 99 ML 08 007), 07/30/99
323	Application by Merchants Bank of California, National Association, Carson, California, to elect the corporate governance provisions of California law and complete a reverse stock split in accordance with those provisions. (Control Number 98 WE 12 124), 08/10/99

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 99-77 , 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 July 15 through August 14.

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.