Corporate Applications:

Vol. 12, No. 11

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
867	Islamic Murabaha financing transactions, whereby a national bank acquires the property on behalf of the customer and then resells the property to the customer at a mark up on an installment basis, are permissible for national banks as part of the business of banking. 06/01/99
868	Letter permits bank, as part of an overall enterprise with an unrelated company, to make a minority investment in the company by receiving, retaining, and -- at some future date -- exercising warrants to acquire stock in the company. 08/16/99
869	Letter finds that national bank may adopt corporate governance provisions of Alabama state law and engage in a share exchange to ensure that newly formed parent holding company will own 100 percent of shares of bank. 10/12/99
870	Letter finds that national bank may adopt corporate governance provisions of Washington state law and engage in a share exchange to ensure that newly formed parent holding company will own 100 percent of shares of bank. 10/12/99
871	National bank may acquire direct non-controlling investment in commercial finance company LLC engaged in the business of making secured and unsecured loans to owners, operators and third-party landlords of franchised, licensed or branded retail businesses. LLC may also engage, either directly or through subsidiaries not yet established, in assisting customers in private placements of debt and equity on an agency basis. 10/14/99

CRA Decisions

Letter No.	Topic
100	Application to merge Provident Bank, Dallas, Texas, into Inwood National Bank, Dallas, Texas, under the charter and title of Inwood National Bank. (Control Number 1999 SW 02 0036), 10/14/99
101	Application to merge Southern California Bank, Newport Beach, California and Santa Monica Bank, Santa Monica, California, into U.S. Bank National Association, Minneapolis, Minnesota, under the charter and title of U.S. Bank National Association. (Control Number 1999 MW 02 0025), 10/29/99

Corporate Decisions

Letter No.	Topic
99-34	Application to convert Bank of America FSB, Salt Lake City, Utah, into Bank of America Utah, National Association, Salt lake City, Utah, and thereupon to merge with and into Bank of America, National Association, Charlotte, North Carolina. (Control Numbers 1999 ML 01 0004 & 1999 ML 02 0026), 10/01/99
99-35	Request of First National Bank of Omaha, Omaha, Nebraska, for approval to expand the activities of an existing operating subsidiary to include adding links to merchant processing-related third party vendors on its Internet site. (Control Number 1999 MW 08 0022), 10/20/99
99-36	Application by Huntington National Bank, Columbus, Ohio, to establish an operating subsidiary to reinsure mortgage insurance. (Control Number 1999 CE 08 0021), 10/29/99
99-37	Application by Wachovia Bank, National Association, Winston-Salem, North Carolina, to establish an operating subsidiary to reinsure mortgage insurance. (Control Number 1999 SE 08 0038), 10/29/99
99-38	Application by Broadway National Bank, Chelsea, Massachusetts to acquire an insurance agency as an operating subsidiary. (Control Number 1999 NE 08 0038), 10/29/99

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

Letter No.	Topic
331	Application by National Bank of Commerce, Memphis, Tennessee, to expand the activities of its operating subsidiary, NBC Capital Markets Group, Inc., to engage in various securities activities including underwriting and dealing in corporate bonds, dealing in and privately placing trust preferred securities and buying and selling collateralized mortgage obligations. (Control Number 1999 WO 08 0012), 11/03/99
332	Application by Chase Manhattan Bank, USA, National Association Wilmington, Delaware, First Union National Bank, Charlotte, North Carolina, and Wells Fargo Bank, San Francisco, California, to invest in a limited liability company through de novo and existing operating subsidiaries. (Control Number 1999 WO 08 014), 10/18/99
333	Application for approval for PNC Mortgage Corp. of America, a wholly-owned operating subsidiary of PNC Bank, NA, to hold a non- controlling minority interest in MERSCORP, Inc. (Control Number 1999 NE 08 0037), 10/19/99
334	Application by Citibank, National Association, New York, New York, to expand the activities of an existing operating subsidiary, Citicorp Mortgage, Inc., to act as agent in selling certain credit related insurance products. (Control Number 1999 ML 08 0005), 10/30/99

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 99-109, 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 October 15 through November 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.