Corporate Applications:

Vol. 11, No. 2

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
817	Letter clarifies status of certain fees as "interest" following termination of credit card account where outstanding balance remains on the account. (01/07/98)
818	Letter outlines three methods by which loan proceeds could be delivered to borrowers at LPOs without violating branching restrictions: 1) disbursal via correspondent bank cashier's check; 2) LPO employee drawing check on correspondent bank; and 3) escrow agent drawing check on own account. (01/12/98)
819	Letter permits a national bank to acquire and hold a non-controlling investment (50%) in a Tennessee LLC, established as a general insurance agency in a place of less than 5,000. (01/21/98)
820	Letter states that financial institutions should collect and report (if required), the gross annual revenue or income of a small business or consumer borrower, rather than the adjusted gross annual revenue or income of the borrower. (01/27/98)

CRA Decisions

Letter No.	Topic
79	Application by Intercontinental National Bank, San Antonio, Texas, to establish a domestic branch. (12/03/97)

Corporate Decisions

Letter No.	Topic
98-05	Application of First National Bank of Ashland, Ashland, Alabama, to purchase certain assets and assume certain liabilities ("The Ashland and Tuskegee branches") of SouthTrust Bank, N.A., Birmingham, Alabama; (Control Number 97SE020048), (11/14/97).
98-06	Application to merge Argentbank, Thibodaux, Louisiana, with and into Hibernia National Bank, New Orleans, Louisiana, under the charter and title of Hibernia National Bank; (Control Number 97SWO20085), (01/08/98).
98-07	Application to merge Sun World, National Association, Santa Teresa, New Mexico, with and into NationsBank, National Association, Charlotte, North Carolina; (Control Number 97ML020039), (01/15/98).
98-08	Application to merge Bank of Miami, Miami, Oklahoma, into The First National Bank and Trust Company of Miami, Miami, Oklahoma, under the charter and title of The First National Bank and Trust Company of Miami; (Control Number 97MW020087), (01/27/98).
98-09	Application of Star Bank, National Association, Cincinnati, Ohio, to purchase and assume all of the assets and liabilities of Great Financial Bank, FSB, Louisville, Kentucky; (Control Number 97CE020086), (01/28/98).
98-10	Notification by Mellon Bank, N.A., Pittsburgh, Pennsylvania, of its intent to establish an operating subsidiary to reinsure mortgage insurance; (Control Number 97NE080040), (01/28/98).
98-11	Application to merge Boatmen's First National Bank of Amarillo, Amarillo, Texas, with and into NationsBank of Texas, National Association, Dallas, Texas; (Control Number 97ML020049), (02/03/98).
98-12	Application by Fleet National Bank, Providence, Rhode Island, to purchase certain assets and assume certain liabilities of Advanta National Bank, Wilmington, Delaware; (Control Number 97ML020048), (02/03/98).

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

Letter No.	Topic
268	Application by The Fuller Foundation to charter a national trust bank in Pasadena, California, with the title "Mission Trust Company, National Association." (Control Number 97WE010008), 01/05/98
269	Notification by KeyBank, N.A., Cleveland, Ohio, to establish an operating subsidiary which will acquire and hold a non-controlling minority interest in a limited liability company that will engage in the business of merchant credit and debit card processing, and will also lease point-of-sale terminals to merchants. (Control Number 97CE080052), 01/13/98
270	Application of First Union National Bank, Charlotte, North Carolina to acquire certain subsidiaries of Wheat First Butcher Singer, Inc. and for a bank operating subsidiary to retain a non-controlling minority interest in Mentor Perpetual Advisors, L.L.C. (Control Numbers 97ML08026 thru 028), 01/21/98
271	Application by First Union National Bank, Charlotte, North Carolina to make through an operating subisidary a minority, noncontrolling investment in Integrion Financial Network, L.L.C. (Control Number 97ML080015), 01/28/98

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 98-22 , 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 January 15 through February 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.