Interpretations and Actions: June 1999

Vol. 12, No. 6

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
861	Letter confirms that a national bank may sell certain debt securities in reliance on the abbreviated disclosure procedure of section 16.6 of the OCC's securities offering disclosure regulations where the holding company for the bank is a foreign private issuer that complies with reporting requirements under the Securities Exchange Act of 1934 by filing Forms 20-F and 6-K. 02/05/99
862	Letter concludes that a national bank's captive mortgage reinsurance subsidiary may enter a mortgage reinsurance agreement with a Cayman Islands segregated portfolio company, to reinsure private mortgage insurance on loans originated or purchased by the bank or one of its affiliates. 06/07/99

CRA Decisions

Letter No.	Topic
93	Application to merge National City Trust Company, West Palm Beach, Florida, with and into National City Interim Trust Company (In Organization), West Palm Beach, Florida, under the charter and title of the latter and the application to merge National City Interim Trust Company, West Palm Beach, Florida, with and into National City Bank, Cleveland, Ohio, under the charter and title of the latter. (Control Numbers 99CE020008 & 99CE020009), 05/04/99
94	Application to merge Bank of America National Trust and Savings Association, San Francisco, California, and NationsBank, National Association, Charlotte, North Carolina. (Control Number 98ML020045), 05/20/99
95	Application to merge NBD Bank, National Association, Indianapolis, Indiana, and NBD Bank, Elkhart, Indiana, into and under the charter and title of "Bank One, Indiana, National Association," Indianapolis, Indiana. (Control Number 99ML020011), 05/24/99

Corporate Decisions

Letter No.	Topic
99-12	Application submitted by First National Bank of Paducah, Paducah, Texas, for prior approval to purchase the assets and assume the liabilities of the "West Texas National Bank, Paducah," a branch of The First National Bank in Lockney, Lockney, Texas. (Control Number 99SW020009), 04/01/99
99-13	Application of Union Planters Bank, N.A., Memphis, Tennessee, to merge with Republic National Bank of Miami, Coral Gables, Florida, under the title and charter of Union Planters Bank, National Association, Memphis, Tennessee. (Control Number 99SE020021), 05/19/99
99-14	Application by Farmers & Mechanics National Bank, Frederick, Maryland, to purchase certain assets and assume certain liabilities of the "Fairfield branch," Fairfield, Pennsylvania, of FMB Bank, Baltimore, Maryland. (Control Number 99SE020012), 05/27/99
99-15	Change in Bank Control of Metris Companies, Inc., St. Louis Park, Minnesota, parent of Direct Merchants Credit Card Bank, N.A., Phoenix, Arizona (Bank), by Thomas H. Lee, and individual, Thomas H. Lee Company, a sole proprietorship, Thomas H. Lee Equity Fund IV, Limited Partnership, and THL Equity Advisors IV, Limited Liability Company. (Control Number 99WE110001), 05/28/99

Final Enforcement Actions

Enclosed is a copy of the OCC's news release number 99-58, 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 May 15, 1999 through June, 1999.

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.