The Illinois Office of Banks and Real Estate, Bureau of Banks and Trust Companies ("OBRE"), has compiled this index of activities and investments in which Illinois state-chartered banks and their subsidiaries may engage. While this index is intended to inform state-chartered banks, and persons who might seek a bank charter from OBRE, of their authority, please note that there may be conditions, restrictions or safety and soundness considerations that apply to each of these activities or investments. You or your legal counsel should review the cited statutes, regulations and interpretive letters and, when appropriate, seek clarification or assistance from OBRE with respect to the exercise of a particular power.

Illinois state-chartered banks derive their powers from the Illinois Banking Act ("Act") [205 ILCS 5/1 et seq.]. They may engage in any activity and may make any investment specified in the Act. They may also exercise powers that are incidental and germane to the general business of banking. See Section 3 of the Act [205 ILCS 5/3] and OBRE's rule titled "Powers Incidental and Germane to Carrying on a General Banking Business" [Illinois Administrative Code, Title 38, Part 320]. Additionally, Illinois state-chartered banks have all of the powers granted to national banks and insured savings associations through the Act's so-called "wild card" authority. See Section 5(11) and 5(25) of the Act [205 ILCS 5/5(11), 5(25)]. If a state-chartered bank intends to engage in a new activity or investment that is not permissible for national banks, the state-chartered bank may have to contact the Federal Deposit Insurance Corporation ("FDIC") to determine whether the activity or investment is permissible pursuant to federal regulations. See 12 C.F.R. 362. Again, you should consult your bank's legal counsel or the FDIC to determine whether your bank must obtain the permission of the FDIC for such an activity or investment.

This index is largely based on the May, 1993 FDIC release titled "Equity Investments Permitted for National Banks and Activities Permissible for National Banks and Their Subsidiaries." [FDIC FIL-35-93 (May 10, 1993)]. As stated above, the powers available to national banks are also available to Illinois state-chartered banks. This index updates the 1993 FDIC release and adds relevant Illinois provisions. This index will be updated periodically and any comments are appreciated. You may refer to this index, and other information relating to OBRE, on the Internet at http://www.state.il.us/obr. You may contact our legal staff in Chicago (312-793-7091) or Springfield (217-782-5103).

Acceptances
Bank may sell small denominations in acceptances created by another bank. Such sale is a deposit subject to reserve requirements under Reg. D, unless there is a pro rata transfer of ownership rights. Office of the Comptroller of the Currency ("OCC") Interpretive Letter 268 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,432, 1983 WL 54154, 1983 LEXIS 10 (August 4, 1983); OCC Interpretive Letter 58 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,133, 1978 WL 21877, 1978 LEXIS 14 (September 18, 1978); 12 C.F.R. 7.1007.

Adjustable Rate Mortgages
Bank may extend adjustable rate mortgages. Section 4(2)(b) of Illinois' Interest Act [815 ILCS 205/4(2)(b)]; 12 C.F.R. 34.6.

Advertising
A bank may lawfully advertise any service which it is permitted to perform, including acting as finder in initiating mortgage loan transactions between interested borrowers and third-party lenders. OCC Interpretive Letter dated December 4, 1986, 1986 WL 143890.

Affiliate Facility - Banking Transactions with Affiliate's Customers
Bank may enter into agreement with affiliated bank to conduct banking transactions for each other's customers. Section 5(23) of the Illinois Banking Act [205 ILCS 5/5(23)].

African Development Bank Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite obligations of the African Development Bank in an amount up to 10% of the bank's capital and surplus. 12 C.F.R. 1.3(d), 1.7.

Agent for Bank Customers Purchasing or Selling Real Estate Limited Partnership Interests
Bank's securities brokerage operating subsidiary may act as agent for its customers in the purchase and sale of publicly offered real estate limited partnership interests. OCC Interpretive Letter 420 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,644, 1988 WL 282351, 1988 LEXIS 20 (March 14, 1988).

Agricultural Credit Corporations
Bank may purchase for its own account stock of a corporation organized for the purpose of making loans to farmers and ranchers for agricultural purposes. The bank's investment in such agricultural credit corporation at any one time shall not exceed 20% of its unimpaired capital and surplus, unless the bank owns at least 80% of the corporation. Such investment is also subject to certain notification, review, and approval procedures. 12 U.S.C. 24(Seventh); 12 C.F.R. 5.36.

Annuities - Sale of
Bank may act as agent for sale of variable rate annuities. See Nationsbank of North Carolina, N.A. v. Variable Annuity Life Insurance Co., 513 U.S. 251 (1995), and January 9, 1997 letter to OBRE from Illinois Department of Insurance.

Appraisals
Bank may perform real estate appraisals for loans it originates as well as for other financial institutions. OCC Interpretive Letter 467 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,691, 1989 WL 303675, 1989 LEXIS 10 (January 24, 1989). See also 12 C.F.R. 5.34(e)(3)(ii)(G). But see OBRE Interpretive Letter 93-14 (August 4, 1993), regarding appraisals for "qualified real estate" exception to bank's lending limit.

Arbitrage
Bank may engage in arbitrage activities using financial futures contracts, where the futures contracts are related to instruments in which the bank can underwrite and deal, subject to limitations in Banking Circular 79. OCC Interpretive Letter 422 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,646, 1988 WL 282349, 1988 LEXIS 28 (April 11, 1988).

Armored Car Service
Bank may provide its customers armored car messenger service provided that the service does not constitute branching. 12 C.F.R. 7.1012. See also OBRE Interpretive Letter 91-23 (September 13, 1991).

Asian Development Bank Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite obligations of the Asian Development Bank in an amount up to 10% of the bank's capital and surplus. 12 C.F.R. 1.3(d), 1.7.

Asset Management Activities
Bank may conduct certain asset management activities through its operating subsidiaries. OCC Interpretive Letter 646 (April 12, 1994).

Asset Protection Plans
Bank may offer guaranteed asset protection plans to car loan customers. OBRE Interpretive Letter 94-13 (July 27, 1994).

Asset Securitization
A national bank may securitize and sell assets that it holds, as a part of its banking business. The amount of securitized loans and obligations that a bank may sell is not limited to a specified percentage of the bank's capital and surplus. 12 C.F.R. 1.3(g).

ATM- Alternate Media
Bank may dispense alternate media from its ATMs including public transportation tokens, event tickets, gift certificates, and phone cards. OCC Interpretive Letter 718 (March 14, 1996).

ATM
ATMs which only dispense cash may be established in Illinois at any location and by any establisher. OBRE Interpretive Letter 96-07 (December 4, 1996).

ATM Network - Operation Via Subsidiary
Bank may form an operating subsidiary to enter into a partnership or joint venture with another bank to establish an automated teller machine network, subject to certain conditions. OCC Interpretive Letter 289 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,453, 1984 WL 63797, 1984 LEXIS 27 (May 15, 1984).

ATM Networks
Bank may convert its proprietary automatic teller machine network into a shared network in which it provides services for other banks in the network. OCC No Objection Letter 87-11 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶84,040, 1987 WL 154143, 1987 LEXIS 33 (November 30, 1987); OCC Interpretive Letter 381 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,605, 1987 WL 154130, 1987 LEXIS 13 (May 5, 1987).

Automatic Payment Plan Accounts
Bank may offer automatic payment plan accounts. 12 C.F.R. 7.1018.

Automobile Club Memberships - Finder for
Sales of memberships as agent for an automobile club and receipt of payment for the club's services are not permissible bank activities. However, the bank may charge the automobile club a fee for acting as "finder" by informing bank customers of the automobile club's services, or can sell bank customer lists to the automobile association. OCC No Objection Letter 89-02 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,014, 1989 WL 303771, 1989 LEXIS 25 (April 17, 1989).

Automobile Leasing Via Subsidiary
Bank may operate an automobile leasing program through its subsidiary and may advertise for that program service. OCC Interpretive Letter 97 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,172, 1979 WL, 1979 LEXIS 25 (May 29, 1979).

Balloon Loans
Bank may make either conventional or repurchase balloon loans. OCC Interpretive Letter 364 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,534, 1986 WL 89628, 1986 LEXIS 8 (July 9, 1986).

Bank Mutual Funds
Bank may sell bank mutual funds provided it complies with certain requirements. OCC Interpretive Letter 637 (September 17, 1993). See also OCC Interpretive Letter 656 (March 13, 1995).

Bank Premises
Bank may invest in bank premises or in a corporation holding the bank premises. Section 5(8) of Illinois Banking Act [205 ILCS 5/5(8)]. 12 U.S.C. 29, 371d; 12 C.F.R. 7.1000. See also OBRE Interpretive Letter 93-07.1 (July 2, 1993) (state bank may purchase real estate to exchange for real estate that will be used for bank premises); OBRE Interpretive Letter 93-09 (July 2, 1993) (state bank may purchase real estate for use as employee parking lot); and OBRE Interpretive Letter 91-33 (December 11, 1991) (state bank owned by foreign corporation may purchase residence for use by bank personnel temporarily assigned to Illinois).

Bank Service Corporation
Bank may invest in bank service corporations subject to certain conditions and limitations. The amount invested may not exceed 10% of the bank's paid-in and unimpaired capital and unimpaired surplus, and not more than 5% of the bank's assets may be invested in bank service corporations. 12 U.S.C. 1862; 12 C.F.R. 5.35.

Bank's Own Stock
Illinois state-chartered bank may purchase and hold shares of its own stock as treasury stock. Section 14(6) of Illinois Banking Act [205 ILCS 5/14(6)]. National bank may purchase or hold shares of its own stock only if necessary to prevent loss upon a debt previously contracted and subject to a six-month time limitation. 12 U.S.C. 83; 12 C.F.R. 7.2019.

Banker's Bank Stock
Bank may invest in stock of an FDIC-insured bank or of a holding company which owns or controls an insured bank that is exclusively owned by depository institutions (excepting requisite directors' qualifying shares), which exclusively provides depository institution related services. The bank's investment in any bank or holding company is limited to 10% of the bank's capital stock and paid-in and unimpaired surplus, and the bank shall not acquire more than 5% of any class of voting securities in such bank or holding company. Section 5c of Illinois Banking Act [205 ILCS 5/5c]; 12 U.S.C. 24(Seventh), 27(b).

Billing Services
Bank may provide billing services to physicians and clinics. OCC Interpretive Letter 712 (February 29, 1996).

Bonds - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, underwrite, and hold bonds issued by a state agency, subject to limitations. OCC Interpretive Letter 167 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,248, 1980 WL 42036, 1980 LEXIS 41 (October 28, 1980). See also OCC Interpretive Letter 703 (January 25, 1996), OBRE Interpretive Letter 93-22 (October 28, 1993), OBRE Interpretive Letter 91-18 (July 31, 1991).

Bridge Loans Via Subsidiary
Bank's subsidiary may enter into a general partnership to make short-term bridge loans to finance merchant banking transactions and to provide advice concerning such bridge loans. OCC Interpretive Letter 411 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,635, 1988 WL 282186, 1988 LEXIS 9 (January 20, 1988).

Brokerage Services
Bank may offer advisory and discount brokerage services and automatic investment services. OCC Interpretive Letter 353 [1785-1787 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,523, 1985 WL 73147, 1985 LEXIS 29 (July 30, 1985); OCC Interpretive Letter 562 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,313, 1991 WL 340671, 1991 LEXIS 89 (August 26, 1991); OCC Interpretive Letter &60~ [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,530, 1986 WL 85088, 1986 LEXIS 7 (April 16, 1986); OCC Interpretive Letter 332 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) 85,502, 1985 WL 73125, 1985 LEXIS 18 (March 8, 1985); OCC Interpretive Letter dated June 10, 1974, [1973-1978 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶96,272; 12 C.F.R. §12.1-12.7.

Brokered Deposits
Bank may accept brokered deposits. 12 U.S.C. 1831f.

Business Services
Bank operating subsidiary may furnish services for the internal operations of the bank or its affiliates including accounting, auditing, appraising, advertising and public relations, data processing, and data transmission services, databases, or facilities. 12 C.F.R. §5.34(e)(2)(ii)(B).

Business Trusts
Bank may be a majority participant in a Delaware business trust which would hold and manage bank's investment portfolios. OCC Interpretive Letter 745 (August 26, 1996).

Call Center Facility
Bank may acquire majority interest in a company which operates a call center facility operating programs by which customers may access databases containing information on automobile dealerships. OCC Interpretive Letter 741 (August 19, 1996).

Campaign Contributions
Bank may make political contributions or expenditures to, or on behalf of, state and local candidates or political committees. Bank may also make loans to federal, state, and local candidates or campaign committees. Federal law [2 U.S.C. 441(b)] prohibits bank from making political contributions to federal candidates or national committees in a federal election. OBRE Policies, Procedures and Examination Guideline 2007.

Canadian Government Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite Canadian government obligations to the same extent that it may do so for United States government obligations. 12 U.S.C. 24(Seventh).

Care Facilities
Bank may provide banking services to persons residing in any nursing home, retirement home, or long term care facility and may conduct a banking business at the location on a limited basis. Such a location shall not be considered a branch. Section 44.1 of the Illinois Banking Act [205 ILCS 5/44.1].

Certificates of Deposit - Purchase and Sale of Participation
Bank may purchase certificates of deposit and sell participation interests therein to its customers. OCC Interpretive Letter 385 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,609, 1987 WL 154125, 1987 LEXIS 20 (June 19, 1987). See also OCC Interpretive Letter 649 (May 12, 1994), OBRE Interpretive Letter 89-05 (March 29, 1989).

Certification Authority and Repository (Digital Signatures)
Subject to certain conditions, bank may establish a subsidiary that will act as a certification authority and repository for certificates used to verify digital signatures. Operating Subsidiary Application by Zions First National Bank, Sale Lake City, Utah, Application Control Number: 97-WO-08-0006 (January 12, 1998).

Charitable Contributions
State banks may make reasonable donations for the public welfare or for charitable, scientific, religious or educational purposes. Section 5(6) of the Illinois Banking Act [205 ILCS 5/5(6)]. National banks may contribute to community funds, or to charitable, philanthropic, or benevolent instrumentalities conducive to public welfare such sums as its board of directors may deem expedient and in the interests of the bank, provided that investment in any one project does not exceed 2% of capital and surplus and investment in all such projects does not exceed 5% of capital and surplus. 12 U.S.C. 24(Eighth).

Charitable Trusts
Bank may establish a short-term charitable trust, subject to conditions and limitations. OCC Interpretive Letter 142 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,223, 1980 WL 42015, 1980 LEXIS 29 (May 14, 1980).

Check Certification
Bank may certify checks. 12 U.S.C. 501. See also 12 C.F.R. 5.34(e)(2)(ii)(G).

Check Guarantee Plans
Bank may enter into check guarantee arrangement. See also 12 C.F.R. 5.34(e)(2)(ii)(G).

Circulating Notes
Bank may obtain, issue, and circulate notes according to the provisions of title 62 of the Revised Statutes. 12 U.S.C. 101 et seq.

Closed-End Collective Investment Funds
Bank may offer closed-end collective investment funds as a fiduciary service to qualified employee benefit accounts. Trust Interpretation 208 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,019, 1989 WL 303775, 1989 LEXIS 30 (April 7, 1989).

Coin and Bullion - Investing and Dealing in
Bank may invest and deal in gold, silver and platinum coins, and bullion. Transactions in coins must be based on the metallic content value of the coins and not on their numismatic value to a collector. OCC Interpretive Letter 252 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,416, 1982 WL 54157, 1982 LEXIS 3 (October 26, 1982); OCC Interpretive Letter dated July 29, 1987, 1987 WL 149775; OCC Banking Circular 58, Fed. Banking L. Rep. (CCH) ¶56,368.50; 12 U.S.C. 24(Seventh).

Collateral Property Protection Insurance
Bank and its operating subsidiaries may sell, in connection with an extension of credit from the bank, vendor's single or double interest insurance which gives the borrower the option to continue payment on the loan, to use the insurance proceeds to repair collateral, and to retain the collateral. OCC Interpretive Letter dated June 3, 1986, 1986 WL 143952; OCC Interpretive Letter 91 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,166, 1979 WL 25506, 1979 LEXIS 28 (April 24, 1979).

Collateral Trust Certificates - Issuance by Subsidiary
Bank's operating subsidiary may issue collateral trust certificates. OCC Interpretive Letter 69 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,144, 1978 WL 21859, 1978 LEXIS 8 (October 17, 1978).

Collateralization of Public Deposits
State banks may pledge assets to collateralize deposits of public funds by federal, State or local public agencies. Section 5(7)(c) and (d) of the Illinois Banking Act [205 ILCS 5/5(7)(c) and (d)]. See also OBRE Interpretive Letter 91-06 (March 14, 1991), OBRE Interpretive Letter 91-04 (February 26, 1991). National bank may collateralize public deposits received from a state or local government authority provided state banks are permitted to do so under state law. OCC Interpretive Letter 527 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,238, 1990 WL 364917, 1990 LEXIS 46 (September 13, 1990).

Collateralized Mortgage Obligations - Issuing and Selling of
Bank may issue and sell CMOs backed by a pool of conventional FHA-guaranteed and VA-insured residential mortgages through an unaffiliated underwriter. OCC Interpretive Letter 378 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,602, 1987 WL 154133, 1987 LEXIS 2 (March 24, 1987). Bank may create mortgage backed pass-through securities by transferring title to pooled mortgages to a trustee. OCC Interpretive Letter 171 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,252, 1980 WL 48458, 1980 LEXIS 40 (November 28, 1980); OCC Interpretive Letter 41 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,116, 1978 WL 21837, 1978 LEXIS 28 (May 18, 1978); OCC Interpretive Letter 123 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,204, 1979 WL 25442, 1979 LEXIS 6 (September 19, 1979); OCC Interpretive Letter 417 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,641, 1988 WL 284801, 1988 LEXIS 15 (February 17, 1988); OCC Interpretive Letter 423 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,647, 1988 WL 242348, 1988 LEXIS 27 (April 11, 1988); OCC Interpretive Letter dated July 7, 1986, 1986 WL 143963; OCC Interpretive Letter dated June 18, 1986, 1986 WL 143957.

Collateralized Mortgage Obligations - Issuing, Underwriting and Dealing in Via Subsidiary
Bank's operating subsidiary may issue, underwrite and deal in evidences of indebtedness (bonds) partially collateralized by pools of mortgages, including GNMA certificates, FNMA certificates, FHLMC certificates, and/or non-federally insured conventional residential mortgage loans. OCC Interpretive Letter 362 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,532, 1986 WL 85093, 1986 LEXIS 5 (May 22, 1986).

Collateralized Mortgage Obligations - Purchase of
Bank may purchase without limit collateralized mortgage obligations that meet the requirements of 12 U.S.C. 24(Seventh). OCC Interpretive Letter dated April 16, 1987, 1987 WL 149796.

Commercial Paper Placement
Bank may place third party commercial paper. OCC Interpretive Letter 329 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,499, 1985 WL 73140, 1985 LEXIS 24 (March 4, 1985). See also OCC Interpretive Letter 627 (July 13, 1993).

Commercial Paper - Sale of Affiliates
Bank may sell an affiliate's commercial paper. OCC Interpretive Letter 24 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,099, 1978 WL 21824, 1978 LEXIS 39 (February 24, 1978).

Commodities Futures
Subject to restrictions, bank's operating subsidiary may act as commodity futures commission merchant for exchange-traded futures. OCC Interpretive Letter 507 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,205, 1990 WL 364908, 1990 LEXIS 22 (May 5, 1990). See also OCC Interpretive Letter 684 (August 4, 1995), OCC-IL-632 (June 30, 1993).

Commodities Futures and Options - Dealing in Via Subsidiary
Bank's operating subsidiary may execute customer transactions for institutional and individual customers, in commodity futures and options on commodity futures contracts, for currency, gold and silver bullion, and stock indices, and may execute customer orders for agricultural and metals futures in connection with customer's hedging with respect to underlying loans from the bank. OCC Interpretive Letter dated June 13, 1986, 1986 WL 143993; OCC Interpretive Letter 356 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,526, 1986 WL 85079, 1986 LEXIS 1 (January 7, 1986).

Commodity Pool Operator
Operating subsidiary may act as general partner and commodity pool operator of a commodity pool. The pool can invest in gold, silver, foreign currency, U.S. government obligations, and Type III investment securities (See 12 C.F.R. 1) and futures and options on such instruments. OCC Banking Circular 79 will limit a bank's ability to conduct this activity unless the bank complies with the limitations stated in OCC Interpretive Letter dated January 30, 1992. OCC Interpretive Letter 496 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,087, 1989 WL 303700, 1989 LEXIS 102 (December 18, 1989); OCC Interpretive Letter 541 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,253, 1991 WL 340649, 1991 LEXIS 9 (February 6, 1991).

Common Trust Funds
Banks may operate common trust funds. Investment Securities Letter 52 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,325, 1991 WL 340587, 1991 LEXIS 116 (July 26, 1991); Trust Interpretation 220 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,036, 1989 WL 303744, 1989 LEXIS 46 (May 26, 1989); Trust Interpretation 200 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,003, 1989 WL 303719, 1989 LEXIS 15 (February 3, 1989).

Community Development Corporations
A State bank may invest in community development corporations or projects, provided that the bank's total investment in such corporation(s) or project(s) does not exceed 10% of the bank's unimpaired capital and unimpaired surplus. Section 5(21) of the Illinois Banking Act [205 ILCS 5/5(21)], as amended by Public Act 90-301 effective August 1, 1997. See also OBRE Interpretive Letter 89-16 (December 28, 1989) and OBRE Interpretive Letter 90-25 (December 14, 1990). National banks may have an equity interest in projects of a predominantly civic, community, or public nature to the extent such investment does not exceed 2% of its capital and surplus and its aggregate investment in all such projects does not exceed 5% of its capital and surplus (10% with approval of OCC). 12 U.S.C. 24(Eighth); OCC Banking Bulletin 91-18 Fed. Banking L. Rep. (CCH) 37,347D, 1991 WL 434642 (May 9, 1991); OCC Advisory Letter No. 92-3 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶88,779 (Feb. 20, 1992); OCC Banking Bulletin 92-37, Fed. Banking L. Rep. (CCH)¶ 59,349, 1992 WL 323848 (July 8, 1992); OCC Interpretive Letter No. 603, Fed. Banking L. Rep. (CCH) ¶83,437, 1992 WL 235140 (August 31, 1992).

Computer Hardware Sales
Bank and its operating subsidiaries may sell computer hardware if it is part of a data processing service package being offered by the bank. OCC Interpretive Letter 345 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,515, 1985 WL 73137, 1985 LEXIS 2 (July 9, 1985).

Computer Networking Packages
Bank operating subsidiaries may provide computer networking packages for other financial institutions. OCC Interpretive Letter 754 (November 6, 1996).

Consumer Access/ Discount Card Program
Bank may establish a subsidiary to operate a consumer access/ discount card program. OCC Interpretive Letter 678 (July 6, 1995).

Consumer Loans
Bank may use an affiliated bank to originate and close consumer loans. OCC Interpretive Letter 721 (March 6, 1996).

Convertible Securities
Bank may purchase securities convertible into stock provided that convertibility is not at the option of the issuer. 12 C.F.R. 1.9.

Copper
Bank may buy and sell copper. OCC Interpretive Letter 693 (November 14, 1995).

Correspondent Services
Bank may provide any of a wide range of services that reflect and incorporate the unique nature of the banking business for other financial institutions. OCC Interpretive Letter 137 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,218, 1979 WL 25446,1979 LEXIS 1 (December 27, 1979). Bank may offer deposit account correspondent services (traditional "back office" operations) to affiliated banks. OCC Interpretive Letter 493 [1989 1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,078, 1989 WL 303697, 1989 LEXIS 92 (November 22, 1989).

Courier Service
Bank may establish a deposit courier service provided it complies with the requirements for a branch, or customers may use an independent third party to provide the service. OBRE Interpretive Letter 94-25 (December 1, 1994). See also 12 C.F.R. 5.34(e)(2)(ii)(F).

Credit Card Bank
Bank may establish a credit card bank as a subsidiary. OCC Interpretive Letter 565 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,319, 1991 WL 340662, 1991 LEXIS 103 (November 27, 1991). See also OBRE Interpretive Letter 91-13 (June 24, 1991).

Credit Card Customer Lists - Sale of
Bank may sell credit card customer lists to an insurance agency that offers cancer insurance. OCC Interpretive Letter 316 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,486, 1984 WL 63822, 1984 LEXIS 4 (December 4, 1984).

Credit Card Processing
Bank may acquire and hold a non-controlling minority interest in a limited liability company which will engage in the business of merchant credit and debit card processing. OCC Interpretive Letter 813 (October 14, 1997).

Credit Card Receivables Securitization
Bank's operating subsidiary may securitize credit card receivables. OCC Interpretive Letter 540 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,252, 1990 WL 364928, 1990 LEXIS 58 (December 12, 1990).

Credit Cards
Bank may issue credit cards directly or through a subsidiary. See OCC Interpretive Letter 720 (January 26, 1996), OCC Interpretive Letter 659 (March 31, 1995), OBRE Interpretive Letter 91-13 (June 24, 1991).

Credit Life Insurance - Sale of
Bank may act as agent for the sale of decreasing term life insurance for its loan customers as a form of credit life insurance. Some restrictions on commission arrangements apply. OCC Interpretive Letter dated March 30, 1987, 1987 WL 149769; OCC Interpretive Letter 330 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,500, 1985 WL 73123, 1985 LEXIS 11 (March 21, 1985); OCC Interpretive Letter 152 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,233, 1980 WL 42024, 1980 LEXIS 24 (June 17, 1980); OCC Interpretive Letter 9 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,084, 1977 WL 23304, 1977 LEXIS 1 (December 28, 1977); OCC Interpretive Letter dated November 21, 1977, [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,069; OCC Interpretive Letter 8 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,083, 1977 WL 23303, 1977 LEXIS 6 (December 23, 1977); OCC Interpretive Letter 18 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,093, 1978 WL 21867, 1978 LEXIS 47 (January 12, 1978). Incentive program to encourage loan officers to sell credit life insurance permissible if it adheres to OCC guidelines. OCC Interpretive Letter 45 [19781979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,120, 1978 WL 21841, 1978 LEXIS 29 (May 15, 1978); OCC Interpretive Letter 26 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,101, 1978 WL 21825, 1978 LEXIS 38 (February 27, 1978). Bank may act as agent for the sale of credit life insurance and receive income in the form of commissions as well as reimbursement for services rendered. It may also acquire a group credit life insurance policy and provide coverage to loan customers. 12 C.F.R. 2.4, 2.6.

Credit Life Insurance - Underwriting of
Bank may acquire, as an operating subsidiary, an insurance company that is engaged in the business of underwriting, as a reinsurer, credit life and credit accident and health insurance in connection with loans made by the bank and its subsidiaries. OCC Interpretive Letter 277 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,441, 1983 WL 54162, 1983 LEXIS 22 (December 21, 1983).

Credit Life Insurance and Disability Insurance Via Subsidiary
Bank's subsidiary may act as agent for credit life and disability insurance as long as the insurance is offered in conjunction with the loans made by the bank. OCC Interpretive Letter 495 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,084, 1989 WL 303705, 1989 LEXIS 100 (December 22, 1989); OCC Interpretive Letter 283 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,447, 1984 WL 63791, 1984 LEXIS 37 (March 16, 1984).

Crop Insurance
Bank may offer, as agent, crop insurance (i.e. multiple peril crop insurance and hail/fire insurance) in connection with loans to its farmer customers. OCC Interpretive Letter 812 (December 29, 1997).

Currency Options
Bank's operating subsidiary may act as a broker-dealer and market maker of exchange-traded options on foreign currencies so that it can execute trades for its own account, the account of the bank, and the accounts of customers. OCC Interpretive Letter 372 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,542, 1986 WL 85085, 1986 LEXIS 16 (November 7, 1986); OCC Interpretive Letter 390 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,614, 1987 WL 154120, 1987 LEXIS 25 (July 28, 1987); OCC Interpretive Letter 384 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,608, 1987 WL 154129, 1987 LEXIS 15 (May 19, 1987).

D&O Mutual Insurance Company
Bank may participate as policyholder in a mutual insurance company established to provide blanket bond and director and officer liability insurance to the banking industry. OCC Interpretive Letter dated October 22, 1986, 1986 WL 143884.

Data Processing Equipment - Leasing of
Bank's operating subsidiary may enter into a general partnership with a corporation for the leasing of electronic data processing equipment on a net, full-payout basis. OCC Interpretive Letter 369 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,539, 1986 WL 85082, 1986 LEXIS 13 (September 25, 1986).

Data Processing Services
Bank may offer data processing and data transmission services.  OBRE Interpretive Letter 98-11 (September 8, 1998). OCC Interpretive Letter dated May 1, 1987, 1986 WL 149765; OCC Interpretive Letter dated April 25, 1986, 1986 WL 143931; OCC Interpretive Letter dated August 3, 1977, [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,003; OCC Interpretive Letter 449 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,673, 1988 WL 284819, 1988 LEXIS 79 (August 23, 1988); OCC Interpretive Letter 346 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,516, 1985 WL 73138, 1985 LEXIS 3 (July 31, 1985); OCC Interpretive Letter 345 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,515, 1985 WL 73137, 1985 LEXIS 2 (July 9, 1985); OCC Interpretive Letter 284 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,448, 1984 WL 63792, 1984 LEXIS 36 (March 26, 1984); 12 C.F.R. §7.1019. See also OCC Interpretive Letter 677 (June 28, 1995), OCC Interpretive Letter 653 (December 22, 1994), 12 C.F.R. §5.34(e)(2)(ii)(H).

Debit Card Processing
Bank may acquire and hold a non-controlling minority interest in a limited liability company which will engage in the business of merchant credit and debit card processing. OCC Interpretive Letter 813 (October 14, 1997).

Debt Cancellation Contracts
Bank may establish reserves against losses arising from cancellation of outstanding debt upon death of borrower by establishing additional charges. OBRE Interpretive Letter 94-11 (June 15, 1994). See also 12 C.F.R. 7.1013; OCC-IL-640 (January 7, 1994).

Debt Collection and Asset Management Services - RTC
Bank may perform debt collection and asset management services for the RTC, if the assets for which the bank is performing the services were assets that the bank did not acquire when it purchased a thrift from the RTC. OCC Interpretive Letter 498 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,089, 1989 WL 303702, 1989 LEXIS 104 (December 26, 1989); OCC Interpretive Letter 538 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,249, 1991 WL 340647, 1991 LEXIS 2 (January 8, 1991).

Debt Collection Via Subsidiary
Bank may establish an operating subsidiary to perform debt collection activities. OCC Interpretive Letter 53 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,128, 1978 WL 21846, 1978 LEXIS 53 (June 27, 1978).

Debt/Equity Swap Participation
Bank may swap debt for equity and acquire equity interests in satisfaction of debts previously contracted where the bank demonstrates that its purpose is to recover the amounts lent and not merely to speculate. There is no requirement that the equity interest in the real property have been pledged as collateral for the debt. OCC No Objection Letter 89-01 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,009, 1989 WL 303722, 1989 LEXIS 20 (January 25, 1989); OCC No Objection Letter 88-7 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶84,047, 1988 WL 284871, 1988 LEXIS 35 (May 20, 1988).

Debt for Equity Swaps
Banks may enter into swaps of rescheduled foreign government loans through a series of interrelated transactions and hold the equity received to extinguish the debt pursuant to the bank's DPC authority. Since the equitable interests in this case may only be held pursuant to the bank's DPC authority, the equity interests must be disposed of as soon as possible. OCC Interpretive Letter 511 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,213, 1990 WL 364897, 1990 LEXIS 14 (June 20, 1990).

Debt Securities
Bank may offer and sell fixed and variable rate nonconvertible debt securities. OCC Interpretive Letter 655 (March 28, 1995).

Debts Previously Contracted ("DPC") - Holding, Managing and Liquidating Assets Via Subsidiary
Bank may form a subsidiary for the purpose of holding, managing and liquidating assets acquired DPC. Section 5(12)(a) of the Illinois Banking Act [205 ILCS 5/5(12)(a)]. See also OBRE Rule titled "Administration of Assets Obtained in Collection of Debt" [Illinois Administrative Code, Title 38, Part 354]; OBRE Interpretive Letter 91-22 (September 12, 1991); OCC Interpretive Letter 355 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,525, 1985 WL 37149, 1985 LEXIS 31 (December 10, 1985); OCC Interpretive Letter 397 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,621, 1987 WL 149896, 1987 LEXIS 44 (September 15, 1987); OCC Interpretive Letter 657 (March 31, 1995).

Deferred Fee and Death Benefit Insurance on Directors
Bank may purchase insurance to protect its interests, including interests in the performance of its personnel. OCC Interpretive Letter 401 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,625, 1987 WL 149900, 1987 LEXIS 48 (November 13, 1987). See also OBRE Interpretive Letter 90-13 (August 8, 1990).

Deposit of Funds in Savings and Loan Associations
Bank may deposit its funds in mutual savings and loan associations, subject to certain conditions and limitations. OCC Interpretive Letter dated October 11, 1977 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,062.

Depository Receptacles
Bank may operate a depository receptacle that is accessible through an ATM, but may not operate a stand-alone, off-premises depository receptacle. OBRE Interpretive Letter 92-04 (May 14, 1992). See also OBRE Interpretive Letter 94-10 (June 15, 1994).

Deposit Placement - Agent for
Bank may act as an agent and place deposits in other financial institutions for its customers. Investment Securities Letter 32 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,038, 1988 WL 284919, 1988 LEXIS 134 (December 2, 1988). See also OBRE Interpretive Letter 89-05 (March 29, 1989).

Deposits
Bank may receive deposits. Section 3 of the Illinois Banking Act [205 ILCS 5/3]; 12 U.S.C. 24(Seventh).

Derivatives
Bank may establish an operating subsidiary to engage in certain derivatives-related activities. OCC Interpretive Letter 725 (May 10, 1996). See also OBRE Interpretive Letter 95-15 (December 20, 1995), OBRE Interpretive Letter 94-19 (September 15, 1994).

Development Credit Corporation
Bank may invest in a development credit corporation that makes loans for its own account without violating branching laws. OBRE Interpretive Letter 91-32 (December 5, 1991).

Digital Signatures
Subject to certain conditions, bank may establish a subsidiary that will act as a certification authority and repository for certificates used to verify digital signatures. Operating Subsidiary Application by Zions First National Bank, Sale Lake City, Utah, Application Control Number: 97-WO-08-0006 (January 12, 1998).

Directors, Officers in Derivative Suits - Indemnification of
Bank may provide for indemnification of directors, officers, and employees. Section 5(19) of the Illinois Banking Act [205 ILCS 5/5(19)]; OBRE Interpretive Letter 91-16 (July 12, 1991); 12 C.F.R. 7.2014; OCC Interpretive Letter 404 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,628, 1987 WL 149902 (March 5, 1987). See also Section 39(b) of the Illinois Banking Act [205 ILCS 5/39(b)] (State bank's charter may limit personal liability of directors).

Directors, Officers and Employees - Incentive Plans
State bank may adopt and operate reasonable bonus, profit-sharing, stock-option, pension and similar incentive plans for its directors, officers and employees. Section 5(5) of the Illinois Banking Act [205 ILCS 5/5(5)].

Directors, Officers - Indemnification of
Bank may, in pursuance of its rights as a creditor, provide for indemnification of a bank employee who serves as a director of a debtor corporation undergoing a Chapter X reorganization. OCC Interpretive Letter dated August 2, 1977 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,002. See also OBRE Interpretive Letter 91-16 (July 12, 1991).

Discount Brokerage Activities
State bank may offer discount brokerage services through affiliation with a registered broker. OBRE Interpretive Letter 89-10 (August 31, 1989).

Discount Brokerage Activities Via Subsidiary
Bank may acquire stock of company as operating subsidiary to perform discount brokerage services and investment advice and to act as a futures commission merchant. OCC Interpretive Letter 380 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,604 (December 29, 1986); OCC Interpretive Letter dated June 30, 1987, 1987 WL 149813; OCC Interpretive Letter 403 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,627, 1987 WL 154114, 1987 LEXIS 37 (December 9, 1987).

Discounting of Promissory Notes
Bank may discount and negotiate promissory notes, drafts, bills of exchange, and other evidences of debt. Section 3 of the Illinois Banking Act [205 ILCS 5/3]; 12 U.S.C. 24(Seventh).

Divestiture of Former Bank Premises
In order to properly divest itself of its entire interest in former bank premises, bank may assign the remainder of a leasehold or may sublease the bank premises if the sublease is for the remainder of the leasehold. OCC Interpretive Letter 491 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,074, 1989 WL 303695, 1989 LEXIS 88 (September 6, 1989).

Dollar Repo/ Dollar Roll Transactions
Bank may engage in fixed coupon dollar repo and dollar roll transactions subject to certain criteria. OBRE Interpretive Letter 89-09 (August 29, 1989).

Drafts and Bills of Exchange
Bank may accept drafts or bills of exchange drawn upon it up to 150% of paid up and unimpaired capital stock and surplus. 12 U.S.C. 372.

Economic Development Loans to Native Americans
Bank may make loans to certain authorized Indian organizations, at least 20% of which loans are guaranteed, without being subject to restrictions of other statutes regarding loan to value ratios, maturity, security, priority of lien or percentage of assets that may be invested. 25 U.S.C.A. 1489.

EFT Network Via Subsidiary
Bank's operating subsidiary may operate an EFT network. OCC Interpretive Letter 289 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,453, 1984 WL 63797, 1984 LEXIS 27 (May 15, 1984); OCC Interpretive Letter 160 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85, 241, 1980 WL 42031, 1980 LEXIS 18 (August 18, 1980). See also OCC Interpretive Letter 664 (May 2, 1995); OBRE Interpretive Letter 92-16 (October 26, 1992).

Electronic Capacities
Bank may market and sell to third parties electronic capacities acquired or developed by the bank in good faith for banking purposes. 12 C.F.R. 7.1019.

Electronic Imaging Services
Bank may hold a minority interest in a company which markets electronic imaging services to banks and other financial services companies and non-financial services companies for use with financial data. In addition, the company may utilize its excess capacity to provide limited services to non-financial data. OCC Interpretive Letter 805 dated October 9, 1997.

Electronic Funds Transfer Switch
Bank may form an operating subsidiary to enter into a general partnership to provide an electronic funds transfer switch for use by financial institutions. OCC Interpretive Letter 382 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,606, 1987 WL 154131, 1987 LEXIS 12 (May 5, 1987).

Electronic Means and Facilities
Bank may perform, provide, or deliver through electronic means and facilities any activity, function, product, or service that it is otherwise authorized to perform, provide, or deliver. 12 C.F.R. 7.1019.

Electronic Services - Commodity Transaction Settlement
Bank may establish a wholly owned de novo operating subsidiary to engage as general partner in providing electronic information and transaction services and providing an electronic gateway for financial settlement services in connection with commodities transactions. OCC Interpretive Letter 346 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,516, 1985 WL 73138, 1985 LEXIS 3 (July 31, 1985).

Electronic Toll Collection
Bank and its operating subsidiaries may bid to design, implement, and operate a processing center and facilities for electronic toll collection. OCC Interpretive Letter 731 (July 1, 1996).

Environmental Financing Authority Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite without limitation obligations of the Environmental Financing Authority. 12 U.S.C. 24(Seventh).

Equity Kickers
Bank may take as consideration for a loan a share in the profit, income or earnings from a business enterprise of a borrower. OBRE Rule titled "Loan Agreements Providing for a Bank to Share in Profits, Income or Earnings" [Illinois Administrative Code, Title 38, Part 350]; 12 C.F.R. 7.1006.

Equity Securities, Taken DPC
Bank may hold securities acquired in good faith by way of compromise of a doubtful claim or to avoid a loss in connection with a debt previously contracted. OBRE Interpretive Letter 97-02 (March 11, 1997); OCC Interpretive Letter No. 511 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,213, 1990 WL 364897 (June 20, 1990).

European Bank for Reconstruction and Development Obligations Purchase of, Dealing in,
and Underwriting of
Bank may purchase, deal in, and underwrite obligations of the European Bank for Reconstruction and Development in an amount up to 10% of the bank's capital and surplus. 12 U.S.C. 24(Seventh); 12 C.F.R. 1.3(d), 1.7.

Exchange-Traded Futures Contracts
Banks may engage in any type of exchange-traded futures contracts for the benefit of its trust accounts. OCC Interpretive Letter 301 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,471, 1984 WL 63830, 1984 LEXIS 26 (June 14, 1984).

Exchange-Traded Options
Bank may purchase and sell for its own account exchange-traded options on fixed-income securities that themselves are permissible investment for national banks, subject to certain requirements. OCC Interpretive Letter 260 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,424, 1983 WL 54147, 1983 LEXIS 15 (June 27, 1983).

Federal Agricultural Mortgage Corporation
Bank may purchase stock in the Federal Agricultural Mortgage Corporation, subject to certain limitations. OCC Interpretive Letter No. 427 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,651, 1988 WL 282345 (May 9, 1988). See also OCC Interpretive Letter 663 (June 8, 1995).

Federal Farm Loan obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in and underwrite without limitation obligations issued under authority of the Federal Farm Loan Act, as amended. 12 U.S.C. 24(Seventh).

Federal Financing Bank Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite without limitation obligations of the Federal Financing Bank. 12 U.S.C. 24(Seventh).

Federal Funds Transactions with Investment Company
Bank may engage in federal funds transactions with an investment company so long as it complies with OCC Banking Circular 112. OCC Interpretive Letter dated February 22, 1985, 1985 WL 73084.

Federal Home Loan Bank Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite without limitation obligations issued by the thirteen banks for the cooperatives of any of them or the Federal Home Loan Banks. 12 U.S.C. 24(Seventh).

Federal Home Loan Bank Stock
Bank may own shares of stock issued by a Federal Home Loan Bank subject to limitations in 12 U.S.C. 1424(a). OBRE Interpretive Letter 90-10 (June 29, 1990). See also 12 U.S.C. 1424, 1426.

Federal Home Loan Mortgage Corporation Stock
Bank may underwrite, deal in, and purchase for its own account preferred stock of the FHLMC issued under 306(f) of the Federal Home Loan Mortgage Corporation Act, taking into consideration the supervisory policies outlined by the OCC. OCC Interpretive Letter No. 577 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,347, 1992 WL 198431 (April 6, 1992). See also OBRE Interpretive Letter 92-05 (May 14, 1992).

Federal National Mortgage Association Stock
Bank may own stock in FNMA. OBRE Interpretive Letter 87-02 (January 27, 1987); OBRE Interpretive Letter 96-02 (March 18, 1996). See also 12 U.S.C. 1718(f).

FHA and Conventional Mortgages - Purchase and Sale of
Bank's operating subsidiary may act as agent for the purchase and sale of FHA and conventional mortgages within the specific constraints of 12 U.S.C. 24(Seventh). OCC Interpretive Letter 28 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,103, 1978 WL 21827, 1978 LEXIS 42 (February 13, 1978).

FHLMC Mortgages - Purchase of, Dealing in and Underwriting of
Bank may purchase, deal in, and underwrite without limitation mortgage, obligations, or other securities which are or ever have been sold by the Federal Home Loan Mortgage Corporation pursuant to Section 305 or Section 306 of the Federal Home Loan Mortgage Corporation Act [12 U.S.C.A. 1434 or 1455]. 12 U.S.C. 24(Seventh). See also OBRE Interpretive Letter 92-05 (May 13, 1992).

Financial Advice and Counseling
Bank may offer strategic planning of a financial nature and market economic information to customers in general. Bank may also offer a wide range of consulting services to correspondent banks. Investment advice may be given through a subsidiary. OCC Interpretive Letter 137 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,218, 1979 WL 25446, 1 (December 27, 1979); OCC Interpretive Letter 367 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,537, 1986 WL 89625, 1986 LEXIS 9 (August 19, 1986); OCC Interpretive Letter dated October 15, 1987, 1987 WL 149785; OCC Interpretive Letter dated July 17, 1986, 1986 WL 143970; OCC Interpretive Letter dated June 30, 1987, 1987 WL 149813; OCC Interpretive Letter 658 (April 27, 1995), OCC-IL-648 (May 4, 1994); OCC Interpretive Letter 647 (April 15, 1994), 12 C.F.R. 5.34(e)(2)(ii)(C), (I). See also OBRE Interpretive Letter 89-07 (June 18, 1989).

Financial Advice and Counseling for Mutual Funds
Bank's operating subsidiary may offer investment advice to a mutual fund. OCC Interpretive Letter 403 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,627, 1987 WL 154114, 1987 LEXIS 37 (December 9, 1987).

Financial Data Processing
Bank may collect, transcribe, process, analyze and store for itself and others, banking, financial, or related economic data. OCC Interpretive Letter 653 (December 22, 1994).

Financial Options
Bank's operating subsidiary may purchase or sell options on financial instruments and options on contracts for future delivery of financial instruments for its own account or as agent for its customers subject to the limitations in OCC Banking Circular 79. OCC Interpretive Letter 357 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,527, 1986 WL 85091, 1986 LEXIS 3 (February 26, 1986); OCC Interpretive Letter 494 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,083, 1989 WL 303704, 1989 LEXIS 99 (December 20, 1989); OCC Banking Circular 79 (3rd rev.), [1982-1983 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶99,539 (April 19, 1983); OCC Interpretive Letter 260 [19831984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,424, 1983 WL 54147, 1983 LEXIS 15 (June 27, 1983); OCC Interpretive Letter dated August 8, 1986, 1986 WL 143973.

Finder
Bank may act as finder to bring a buyer and seller together. 12 C.F.R. 7.1002.

FNMA Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite without limitation obligations, participations, or other instruments of or issued by the Federal National Mortgage Association. 12 U.S.C. 24(Seventh). See also OBRE Interpretive Letter 96-02 (March 18, 1996), OBRE Interpretive Letter 87-02 (January 27, 1987).

Foreign Bank Stock
Bank may hold stock of a foreign bank. 12 U.S.C. 601, 603; 12 C.F.R. 211.5.

Foreign Branches
Bank may establish foreign branches. 12 U.S.C. 601(First).

Foreign Currency Trading Via Subsidiary
Bank's operating subsidiary may buy and sell foreign currency in the spot and forward markets and may buy and sell over-the-counter foreign currency options, subject to certain conditions. OCC Interpretive Letter 414 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,638, 1988 WL 284804, 1988 LEXIS 12 (February 11, 1988); OCC Interpretive Letter 433 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,657, 1988 WL 284812, 1988 LEXIS 37 (June 3, 1988). See also OCC Interpretive Letter 778 (March 20, 1997).

Full Payout Leases
Bank may reasonably rely on the residual value of leased property in structuring a net full payout lease that recoups 100% of the investment plus the cost of handling. OCC Interpretive Letter 20 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,095, 1978 WL 21822, 1978 LEXIS 46 (January 12, 1978); OCC Banking Circular 125 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶97,809 (April 20, 1979).

Futures Commission Merchant
State bank may act as futures commission merchant and may establish a subsidiary to act as futures commission merchant. Bank may establish a subsidiary through acquisition of an SEC-registered broker-dealer and CFTC-registered futures commission merchant engaged in (1) providing brokerage and futures commission merchant services; (2) maintaining membership on exchanges and acting as a clearing member; (3) providing margin financing from a bank branch office; (4) engaging in securities lending by borrowing securities from third parties to re-lend to customers; and (5) holding seats on various exchanges to lease to trading customers. OBRE Interpretive Letter 83-01 (November 30, 1983). See also OCC Interpretive Letter dated December 29, 1986, 1986 WL 143996; OCC Interpretive Letter 624 (June 30, 1993).

General Contractor Licenses
Bank may obtain a license and act as general contractor in order to make appropriate improvements and repairs to its own OREO, subject to certain restrictions. OCC No Objection Letter 91-4 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,318, 1991 WL 338432, 1991 LEXIS 100 (October 11, 1991).

GNMA Futures Market Participation
Bank may participate in GNMA futures markets, subject to conditions outlined in OCC Banking Circular 79. OCC Interpretive Letter dated September 21, 1977 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,037.

GNMA Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite without limitation obligations, participations, or other instruments of or issued by the Government National Mortgage Association. 12 U.S.C. 24(Seventh).

Government Securities - Agent for Sale of
Bank may act as agent for the purchase or sale of government securities on an unsolicited basis, if it holds the securities for customers. See 17 C.F.R. Parts 400 and 450. Investment Securities Letter 31 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,037, 1988 WL 284918, 1988 LEXIS 133 (November 21, 1988). See also OBRE Interpretive Letter 89-05 (March 29, 1989).

Government Securities Clearing Corporation
Bank may invest (purchase shares) in the Government Securities Clearing Corporation, a new subsidiary of National Securities Clearing Corporation. OCC Interpretive Letter 421 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,645, 1988 WL 282350 (March 14, 1988).

Guarantee of Obligations of Others
A bank may lend its credit, bind itself as a surety to indemnify another, or otherwise become a guarantor, if it has a substantial interest in the performance of the transaction involved or has a segregated deposit sufficient in amount to cover the bank's total potential liability. 12 C.F.R. 7.1017, OCC Interpretive Letter 218 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,299, 1981 WL 50495, 1981 LEXIS 14 (September 16, 1981); OCC Interpretive Letter 94 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,169, 1979 WL 25414, 1979 LEXIS 48 (May 3, 1979); OCC Interpretive Letter 237 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,401, 1982 WL 54142, 1982 LEXIS 15 (February 23, 1982). See also OCC Interpretive Letter 738 (August 14, 1996).

Guard Services
Bank's operating subsidiary which provides security and guard services for the bank may also perform such services for affiliated banks and non-banks owned by the parent holding company. OCC Interpretive Letter 398 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,622, 1987 WL 149897, 1987 LEXIS 45 (September 28, 1987).

Holding Collateral Stock as Nominee
Bank may accept transfer as nominee of stock of another bank or other corporation to be held by it as collateral. 12 C.F.R. 7.1009.

Home Banking Services
See also OBRE Interpretive Letter 90-03 (January 30, 1990).

Home Banking Services
Bank subsidiary may provide home banking services via a direct and Internet connection to the bank's home banking system. OCC Interpretive Letter 742 (August 19, 1996). See also OCC Interpretive Letter 677 (June 28, 1995).

Home Equity Lines of Credit
Bank may lend to its customers via home equity lines of credit, and such lines of credit may be offered pursuant to the Illinois Financial Services Development Act ("IFSDA") [205 ILCS 675/1 et seq.]. Interest Act limitations on revolving credit [815 ILCS 205/4.1 and 4.2] do not apply to home equity lines of credit under IFSDA. OBRE Interpretive Letter 96-01 (January 24, 1996).

Homeowners' Associations - Services for
Bank may perform various types of review and analyses required under state law for homeowner associations and their management companies, including projections for future reserve needs, timing of contributions, and economic forecasts. OCC Interpretive Letter dated August 20, 1987, 1987 WL 149774.

HUD Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite without limitation obligations which are insured by the Secretary of Housing and Urban Development under title XI of the National Housing Act [12 U.S.C. 1749aaa et seq.]. 12 U.S.C. 24(Seventh).

HUD Obligations - Purchase of, Dealing in, and Underwriting of HUD Obligations Insured under Section 207 of the National Housing Act
Bank may purchase, deal in, and underwrite without limitation obligations which are insured by the Secretary of Housing and Urban Development pursuant to section 207 of the National Housing Act [12 U.S.C. 1713], if the debentures to be issued in payment of such insured obligations are guaranteed as to principal and interest by the United States. 12 U.S.C. 24(Seventh).

Housing Development Corporations
Bank may purchase stock for its own account in corporations created pursuant to Title IX of the Housing and Urban Development Act of 1968, the purpose of such corporations being to provide low and moderate income housing. 12 U.S.C. 24(Seventh).

Incentive Plans for Directors, Officers and Employees
State bank may adopt and operate reasonable bonus, profit-sharing, stock-option, pension and similar incentive plans for its directors, officers and employees. Section 5(5) of the Illinois Banking Act [205 ILCS 5/5(5)].

Incidental Powers
Bank may conduct all such incidental powers as shall be necessary to carry on the business of banking. Section 3 of the Illinois Banking Act [205 ILCS 5/3]; OBRE Rule titled "Powers Incidental and Germane to Carrying on a General Banking Business" [Illinois Administrative Code, Title 38, Part 320]. See also 12 U.S.C. 24(Seventh).

Indemnification of Directors and Officers
Bank may, in pursuance of its rights as a creditor, provide for indemnification of a bank employee who serves as a director of a debtor corporation undergoing a Chapter X reorganization. OCC Interpretive Letter dated August 2, 1977 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) 85,002. See also OBRE Interpretive Letter 91-16 (July 12, 1991).

Indemnification of Directors and Officers in Derivative Suits
Bank may provide for indemnification of directors, officers, and employees. Section 5(19) of the Illinois Banking Act [205 ILCS 5/5(19)]; OBRE Interpretive Letter 91-16 (July 12, 1991); 12 C.F.R. 7.2014; OCC Interpretive Letter 404 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,628, 1987 WL 149902 (March 5, 1987). See also Section 39(b) of the Illinois Banking Act [205 ILCS 5/39(b)] (State bank's charter may limit personal liability of directors).

Individual Retirement Account
See also OBRE Policies, Procedures and Examination Guideline 2004.

Individual Retirement Accounts ("IRAs")
Bank without trust powers may act as IRA custodian if the individual retirement account funds are held in savings or time deposit accounts. OCC Banking Circular 61 [1973-1978 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶196,445 (January 27, 1975); OCC Interpretive Letter 302 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,472, 1984 WL 63809 (undated).

Industrial Development Revenue Bonds - Purchase and Sale of
Bank may purchase and sell industrial development revenue bonds for its own account. OCC Interpretive Letter 174 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,255, 1980 WL, 48448, 1980 LEXIS 3 (December 16, 1980). See also OBRE Interpretive Letter 93-22 (October 28, 1993).

Information Analysis and Execution Services
Bank's subsidiary may act as general partner in a joint venture providing information analysis and execution services. Standards for subsidiary as general partner set forth with respect to various securities. OCC Interpretive Letter 516 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,220, 1990 WL 364902, 1990 LEXIS 33 (July 12, 1990).

Insurance - Acting as Finder for Insurance Companies
Bank may act as a "finder" for insurance companies or service vendors for its customers. Banks can perform referral and clerical services for the sale of homeowners' insurance to its mortgage loan customers, because this is tantamount to acting as a finder. OCC Interpretive Letter 566 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,320, 1991 WL, 340663 (undated); OCC Interpretive Letter 472 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,008, 1989 WL 303688, 1989 LEXIS 21 (March 2, 1989). See also Article XLIV of the Illinois Insurance Code [215 ILCS 5/1400 et seq.].

Insurance Activities
State bank or its subsidiary may engage in insurance activities as a registered firm, and employees of the State bank or subsidiary may be licensed insurance producers. Section 5(24) of the Illinois Banking Act [205 ILCS 5/5(24)]; Article XLIV of the Illinois Insurance Code [215 ILCS 5/1400 et seq.].

Insurance Contracts for Bank Purposes
See also OBRE Policies, Procedures and Examination Guideline 2006.

Insurance Contracts for Bank Purposes
Bank may purchase insurance contracts for certain legitimate insurance purposes but not for investment purposes. OBRE Interpretive Letter 90-19 (September 14, 1990). See also OBRE Interpretive Letter 95-02 (April 19, 1995), OBRE Interpretive Letter 91-08 (April 11, 1991), OBRE Interpretive Letter 90-13 (August 8, 1990).

Insurance, Crop
Bank may offer, as agent, crop insurance (i.e. multiple peril crop insurance and hail/fire insurance) in connection with loans to its farmer customers. OCC Interpretive Letter 812 (December 29, 1997).

Insurance of Private Deposits Over $100,000
Bank may purchase an insurance company's surety bond to insure private deposits over $100,000. OCC Interpretive Letter 323 [19851987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,493, 1985 WL 73150, 1985 LEXIS 22 (January 8, 1985).

Insurance Purchased to Fund Deferred Compensation Plan
State bank may establish a deferred compensation plan for the benefit of senior bank officers and fund the plan with life insurance contracts without regard to investment limitations. OBRE Interpretive Letter 90-13 (August 8, 1990).

Insurance, Unemployment
Bank may offer involuntary unemployment insurance coverage to its borrowers in the same manner that it may offer credit life insurance and credit accident/ health insurance. OBRE Interpretive Letter 93-24 (November 29, 1993).

Insured Mortgage Investments
Bank's operating subsidiary may act as managing general partner of a Delaware limited partnership dealing in insured mortgage investments. OCC Interpretive Letter 423 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,647, 1988 WL 282348, 1988 LEXIS 27 (April 11, 1988).

Interest Rates
Bank may use the interest rates permitted by the law of its main office state with respect to extensions of credit made to holders of credit cards issued by the Bank regardless of the state in which it resides. 12 U.S.C. 183rd. See also OCC Interpretive Letter 776 (March 18, 1997). See also OCC Interpretive Letter 782 (May 21, 1997), OCC Interpretive Letter 707 (January 31, 1996).

Internet Service Provider
Bank may conduct activity as an Internet Service Provider if the activity is undertaken for the enhancement and support of community development and to enrich the lives and education opportunities for bank customers and community residents. OBRE Interpretive Letter 96-04 (August 14, 1996). See also OCC Interpretive Letter 742 (August 19, 1996).

Inter-American Development Bank Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite obligations of the Inter-American Development Bank in an amount up to 10% of the bank's capital and surplus. 12 C.F.R. 1.3(d), 1.7.

Inter-American Investment Corporation Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite obligations of the Inter-American Investment Corporation in an amount up to 10% of the bank's capital and surplus. 12 C.F.R. 1.3(d), 1.7.

Interbank Debt Obligations
Bank may place debentures without recourse with foreign banks that are not affiliated with U.S. banks. OCC Interpretive Letter 48 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,123, 1978 WL 21878, 1978 LEXIS 22 (June 28, 1978).

International and Foreign Exchange Activities
Bank may establish a branch in a foreign country and engage in international activities upon prior notification of the OCC. 12 U.S.C. 601 et seq., 12 C.F.R. 20.1-20.5.

International Bank for Reconstruction and Development Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite obligations of the International Bank for Reconstruction and Development in an amount up to 10% of the bank's capital and surplus. 12 C.F.R. 1.3(d), 1.7.

International Finance Corporation Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite obligations of the International Finance Corporation in an amount up to 10% of the bank's capital and surplus. 12 C.F.R. 1.3(d), 1.7.

Interstate Branches
Bank may establish and maintain branches in another state (pursuant to that state's law) that may conduct any activity authorized or permitted for any bank that has a charter issued by that state, subject to the same limitations and restrictions that are applicable to banks chartered by that state. Section 5(15b) of the Illinois Banking Act [205 ILCS 5/5(15b)].

Investing in Mortgage-Related Securities Via Mutual Funds
Bank may generally purchase mortgage-related securities and may, therefore, invest in mutual funds which own eligible mortgage-related securities. Investment Securities Letter 15 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,885, 1987 LEXIS 9 (February 11, 1987).

Investment Authority
Bank may delegate its discretionary investment authority to unaffiliated third parties, provided that the bank adopts certain oversight procedures. OBRE Interpretive Letter 92-18 (December 22, 1992).

Investment Portfolio Management
Bank operating subsidiaries may provide investment portfolio management services for the bank. OCC Interpretive Letter 754 (November 6, 1996).

Investment Securities - Purchase for Own Account
Bank may purchase for its own account investment securities, subject to limitations and restrictions. Investment securities are debt obligations that are of investment quality and are readily marketable. Section 33 of the Illinois Banking Act [205 ILCS 5/33]; OBRE Interpretive Letter 94-24 (November 1, 1994); OBRE Interpretive Letter 91-05 (March 2, 1991). See also 12 U.S.C. 24(Seventh); 12 C.F.R. 1.1-1.140; OCC Interpretive Letter 688 (May 31, 1995); OCC Interpretive Letter 687 (September 5, 1995).

Islamic Banking
Bank may offer a residential Net lease home finance product to meet the needs of its customers who adhere to the principals of Islam. OCC Interpretive Letter 806 dated October 17, 1997.

Israel Bonds
Bank may purchase or hold obligations of the State of Israel, or obligations fully guaranteed by the State of Israel as to payment of principal and interest, up to the 20% of the bank's unimpaired capital and unimpaired surplus. Section 34(7) of the Illinois Banking Act [205 ILCS 5/34(7)].

Issuance and Sale of Securities Guaranteed under Section 1721(g) of Title 12
Bank may issue and sell securities which are guaranteed pursuant to section 1721(g) of title 12 of the U.S. Code. 12 U.S.C. 24(Ninth).

Japanese Yen Debentures
Bank may purchase, deal in, underwrite and hold Japanese yen debentures. OCC Interpretive Letter 358 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,528, 1986 WL 85090, 1986 LEXIS 2 (March 26, 1986).

Joint Venture to Facilitate Health Insurance Payments through Shared EFT Technology
Bank may enter into a joint venture with health insurance carriers to form electronic funds transfer system, notwithstanding fact that system will also transmit some treatment information. OCC Interpretive Letter 419 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,643, 1988 WL 284803, 1988 LEXIS 11 (February 16, 1988).

Key Person Insurance
Bank may purchase insurance for benefit of bank on life of a bank officer. See OBRE Interpretive Letter 95-02 (April 19, 1995).

Lease Consulting Services Via Subsidiary
Banks may engage in property leasing activities through a subsidiary, including lease consulting services, finder services, and lease servicing. OCC Interpretive Letter 567 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,337, 1991 LEXIS 124 (October 29, 1991). See also 12 C.F.R. 5.34(e)(2)(ii)(M).

Lease Financing
Bank may engage in lease financing. Section 5(14) and 35.1 of the Illinois Banking Act [205 ILCS 5/5(14) and 5/35.1]. See also 12 C.F.R. Part 23; OCC Banking Bulletin 91-47 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶88,692 (December 3, 1991) OCC Interpretive Letter 806 dated October 17, 1997.

Lease of Bank Property to Third Party
Bank may lease space above its parking garage to a third party for the purpose of erecting an office building if the nonbanking business appears separate from the banking business, the relationship between the two entities is at arms-length, and security problems presented by such an arrangement are considered by the bank. OCC Interpretive Letter dated December 23, 1986, 1986 WL 143883.

Lease of DPC Property
Bank may enter into a lease agreement regarding DPC property, subject to conditions and limitations. OCC Interpretive Letter dated September 2, 1977 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,022

Lease of Public Facilities
Bank may lease a building to a municipality so long as lease agreement provides that municipality will become owner of building upon expiration of lease. OBRE Interpretive Letter 93-27 (December 15, 1993); 12 C.F.R. 7.1000.

Leasing Bank Employees from Third Party
Bank may lease the services of its employees from a third party so long as the board of directors continues to retain and exercise general supervision over the affairs of bank. OCC Interpretive Letter 431, Fed. Banking L. Rep. (CCH) ¶85,655, 1987 WL 154112, 1987 LEXIS 109 (November 5, 1987).

Leasing Bank Lobby to Securities Brokers, Real Estate Brokers
Bank may lease bank premises to unaffiliated entities which engage in brokerage activities and the rental payments made to the bank may be based on a percentage of gross commissions received by the tenant broker. OCC Interpretive Letter 562 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,313, 1991 WL 340671, 1991 LEXIS 89 (August 26, 1991); OCC Interpretive Letter 533 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,244, 1990 WL 364924, 1990 LEXIS 52 (October 5, 1990); OCC Interpretive Letter dated December 11, 1986, 1986 WL 144031; OCC Interpretive Letter dated October 21, 1986, 1986 WL 144030; OCC Interpretive Letter 408 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,632, 1987 WL 154119, 1987 LEXIS 42 (August 4, 1987); OCC Interpretive Letter 407 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,631, 1987 WL 154117, 1987 LEXIS 40 (August 4, 1987); OCC Interpretive Letter 406 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,630, 1987 WL 154118, 1987 LEXIS 41 (August 4, 1987).

Leasing - Equipment and Personal Property
State bank may own and lease personal property acquired at the request of a prospective lessee, provided that the lease and the amount of the bank's investment in the property comply with Section 35.1 of the Illinois Banking Act. Sections 5(14) and 35.1 of the Illinois Banking Act [205 ILCS 5/5(14) and 35.1]. Bank may invest in tangible personal property, including without limitation, vehicles, manufactured homes, machinery, equipment, or furniture, for lease financing transactions on a net lease basis, provided the aggregate book value of all such property does not exceed 10% of the consolidated assets of the bank. 12 U.S.C. 24(Seventh); 12 C.F.R. 23.7; OCC Interpretive Letter 567 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,337, 1991 LEXIS 124 (October 29, 1991); OCC Interpretive Letter 556 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,306, 1991 WL 340664, 1991 LEXIS 85 (August 6, 1991).

Leasing Excess Security/Fire Alarm Capacity
Bank may lease excess monitoring capacity of its security/fire alarm system to other financial institutions. OCC Interpretive Letter dated September 17, 1987, 1987 WL 149789.

Leasing Office Space to Insurance Agent
Bank may lease space to an insurance agent in return for a percentage of sales or gross income, subject to certain conditions. OCC Interpretive Letter 274 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,438, 1983 WL 54161, 1983 LEXIS 23 (December 2, 1983).

Lending on Personal Security
Bank may loan money on personal security. Section 3 of the Illinois Banking Act [205 ILCS 5/3]; 12 U.S.C. 24(Seventh).

Lending Via Draft Authorization Letters
Banks may enter into commitment to lend via draft authorization letter. OCC Interpretive Letter 214 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,295, 1981 WL 50512, 1981 LEXIS 48 (July 23, 1981).

Letters of Credit
Bank may issue a "clean letter of credit" that does not fix a specific expiration date or state a limitation in amount, so long as the instrument permits the bank to terminate its liability within a specified period of time and establishes a daily limit beyond which the bank may not honor the draft. OCC Interpretive Letter 239 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,403, 1982 WL 54144, 1982 LEXIS 13 (March 10, 1982); 12 C.F.R. 7.7016. See also OBRE Interpretive Letter 90-12 (August 3, 1990).

Leveraged Lease
Bank may enter into leveraged leases of personal property which include an incidental interest in real property under 12 C.F.R. Part 23. OCC Interpretive Letter 770 (February 10, 1997).

Life Insurance on Employees
Bank may purchase a single premium life insurance policy for a director in connection with a deferred fee program. OCC Interpretive Letter 401 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,625, 1987 WL 149900, 1987 LEXIS 48 (November 13, 1987). See also OBRE Interpretive Letter 90-13 ((August 8, 1990); OBRE Interpretive Letter 95-02 (April 19, 1995).

Limited Liability Company
Bank may convert operating subsidiaries into limited liability companies. OCC Interpretive Letter 689 (August 9, 1995); OCC Interpretive Letter 668 (October 14, 1994).

Limited Liability Company, Minority Equity Ownership by Bank
State bank may make minority equity investment in a limited liability company, corporation or partnership, subject to specified conditions. OBRE Interpretive Letter 96-06 (October 3, 1996).

Loan on or Purchase by Bank of Own Stock
Bank may make a loan on the security of its own shares or be the purchaser or holder of such shares, only if the security or purchase is necessary to prevent a loss on a debt previously contracted and the purchased stock is sold within six months. 12 U.S.C. 83; 12 C.F.R. 7.2019.

Loan Origination and Servicing Activities
Bank's operating subsidiary may engage in loan origination and servicing activities, as well as commercial mortgage loan brokerage services. OCC Interpretive Letter 387 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,611, 1987 WL 154124, 1987 LEXIS 22 (June 22, 1987). See also OCC Interpretive Letter 636 (July 23, 1993); OCC Interpretive Letter 634 (July 23, 1993).

Loan Participations
Bank may purchase participation interests in pooled loans which are federally guaranteed or insured, subject to safety and soundness restrictions. OCC Interpretive Letter 579 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,349, 1992 WL 266690, 1992 LEXIS 16 (March 24, 1992); OCC Banking Circular 248, 5 Fed. Banking L. Rep. (CCH) ¶66,580B (October 24, 1990).

Loan Participations, Repurchase of Participated Interest
State bank may repurchase portions of a loan participation that the bank had sold provided that the amount of the loan held on its books complies with the statutory lending limit. OBRE Interpretive Letter 95-06 (August 1, 1995).

Loan Production Offices
Bank may establish a loan production office to solicit and originate business outside of its main office and authorized branches provided loans originated at LPOs are approved and made at bank's main office or branch. OBRE Interpretive Letter 91-21(September 4, 1991); OCC Banking Circular 199, office or branch. OBRE Interpretive Letter 91-21 (September 4, 1991); OCC Banking Circular 199, 1 Fed. Banking L. Rep. (CCH) 3,168A (May 23, 1985); 12 C.F.R. 7.1004; OCC Interpretive Letter 691 (September 25, 1995); OCC Interpretive Letter 667 (October 12, 1994). See also OBRE Interpretive Letter 91-17 (March 21, 1991); OBRE Interpretive Letter 88-07 (December 13, 1988).

Loan Repurchase Agreements
Bank may agree to repurchase loans or other assets. OCC Interpretive Letter 752 (September 26, 1996).

Loans to an ESOP
Bank, as a disqualified person who serves as trustee or service provider to an ESOP, may make qualified term loans through its commercial loan division to a company sponsoring an ESOP. OCC Trust Interpretation 241 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,082, 1989 WL 303766, 1989 LEXIS 96 (November 14, 1989).

Local Public Agency Obligations - Purchase of, Dealing in, and Underwriting of
State bank may invest without limitation in general obligations of each municipality located in whole or in part in the county in which the bank is located. Section 35(4) of the Illinois Banking Act [205 ILCS 5/35(4)]. See also OBRE Interpretive Letter 93-19 (October 21, 1993); OBRE Interpretive Letter 93-11 (July 15, 1993); OBRE Interpretive Letter 91-31 (November 25, 1991); OBRE Interpretive Letter 91-18 (July 31, 1991). Bank may purchase, deal in, and underwrite without limitation obligations of any local public agency (as defined in section 110(h) of the Housing Act of 1949 [42 U.S.C.A. 1460(h)]) as are secured by an agreement between the local public agency and the Secretary of Housing and Urban Development. 12 U.S.C. 24(Seventh).

Loan Assets - Purchase and Sale of
Bank's operating subsidiary may purchase loan assets from the bank and sell them to third parties. OCC Interpretive Letter 416 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,640, 1988 WL 284802, 1988 LEXIS 14 (February 16, 1988).

Loan Customer List - Sale to Insurance Agency
Bank may sell list of loan customers to an insurance agency that has a percentage lease arrangement with the bank. OCC Interpretive Letter 316 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,486, 1984 WL 63822, 1984 LEXIS 4 (December 4, 1984). See also Section 1415 of the Illinois Insurance Code [215 ILCS 5/1415] (limitations on the disclosure or use of customer's confidential insurance information by a bank that is a registered firm).

Loans-Finder and Servicer for
Bank may act as finder for agricultural/real estate loans made by another lender; bank may also service these loans. OCC Interpretive Letter dated May 9, 1986, 1986 WL 143944.

Lotteries
Bank can perform lawful banking services for a state operating a lottery or employees administering the lottery. 12 U.S.C. 25a(d).

Management Consulting
Bank operating subsidiaries may provide management consulting, operational advice, and specialized services for other depository institutions. 12 C.F.R. 5.34(e)(2)(ii)(E)

Mandatory Convertible Security - Purchase and Holding of
Bank may purchase mandatory convertible security where the corporation cannot exercise its conversion option prior to a certain date, so long as the bank disposes of the security before that date. OCC Interpretive Letter dated April 22, 1986, 1986 WL 143927.

Margin Lending
Bank's operating subsidiary may make margin loans to customers. OCC Interpretive Letter 326 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,496, 1985 WL 73120, 1985 LEXIS 20 (January 17, 1985).

Marketing of Banking-Related Computer Software
Bank's operating subsidiary may be a general partner with a corporation, where the purpose of the general partnership is to develop and market banking-related computer software to financial institutions and companies that process items for them. OCC Interpretive Letter dated December 6, 1990, 1990 WL 362196.

Marketing of Computer Software
Bank may, as licensee of computer software, market the software with related hardware to other financial institutions as a correspondent service, provided the sale of the hardware does not dominate the overall package. OCC Interpretive Letter dated July 13, 1987, 1987 WL 149776.

Medical Receivables - Factoring of
Bank may directly purchase medical customer account receivables without recourse, including the assumption of the risks and responsibilities of making collection. OCC Interpretive Letter 712 (February 29, 1996).

Membership in Foreign Exchange
Bank's operating subsidiary may engage in exchange membership, floor trading, and market making activities related to foreign exchange subject to certain conditions and restrictions, provided the bank is free from liability arising from the subsidiary's exchange membership. OCC Interpretive Letter 422 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,646, 1988 WL 282349, 1988 LEXIS 28 (April 11, 1988).

Messenger Operations
Bank may expand its messenger operations and offer the excess capacity to correspondent banks. OCC No Objection Letter 89-04 [l989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,061, 1989 WL 303752, 1989 LEXIS 73 (July 11, 1989). See also OBRE Interpretive Letter 88-05 (September 30, 1988); OBRE Interpretive Letter 85-01 (January 16, 1985), OBRE Interpretive Letter 94-25 (December 1, 1994).

Minority Investments
Under certain conditions, bank may make minority investments in limited liability companies, partnerships, and corporations. OBRE Interpretive Letter 96-06 (October 3, 1996); OCC Interpretive Letter 705 (October 25, 1995); OCC Interpretive Letter 692 (November 1, 1995).

Mobile Branches
Bank may establish mobile branches. OBRE Interpretive Letter 93-32 (December 22, 1993).

Money Orders - Sale of
Bank may sell money orders at non-bank locations. 12 C.F.R. 7.1014. See also 12 C.F.R. 5.34(e)(2)(ii)(D).

Mortgage Banking Subsidiary
Bank may establish an operating subsidiary which will be a mortgage company that will operate as a mortgage company in its own right, as well as holding the outstanding voting stock in three mortgage companies that the bank now owns directly and will perform management, administrative, and operational activities for the companies. OCC Interpretive Letter dated December 19, 1986, 1986 WL 143894.

Mortgage Collateral Warehousing
Bank's operating subsidiary may warehouse mortgage collateral for a lender other than its parent bank, and in connection with this activity it may receive, verify, and store documentation relating to loans and collateral. OCC Interpretive Letter dated May 28, 1986, 1986 WL 143948.

Mortgage Lender
Bank may directly own a 45% interest in a mortgage lender. OCC Interpretive Letter 711 (February 23, 1996).

Mortgage Reinsurance
Bank may establish a subsidiary to reinsure a portion of the mortgage insurance on loans originated or purchased by the bank or its affiliates. OCC Interpretive Letter 743 (October 17, 1996).

Mortgage Related Securities
Bank is generally allowed to purchase mortgage-related securities and may therefore invest in mutual funds which own eligible mortgage-related securities. Investment Securities Letter No. 15 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,885 (February 11, 1987).

Mortgage Related Securities - Investing in Via Mutual Funds
Bank may generally purchase mortgage-related securities and may, therefore, invest in mutual funds which own eligible mortgage-related securities. Investment Securities Letter 15 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,885, 1987 LEXIS 9 (February 11, 1987).

Mortgage Servicing Operation Via Subsidiary
Bank may expand the activities of its operating subsidiary to include being a 50% equity partner and sole general partner in a limited partnership formed for the purpose of conducting a mortgage servicing operation. OCC Interpretive Letter dated July 23, 1986, 1986 WL 143932. See also OCC Interpretive Letter 645 (April 29, 1994).

Municipal Finance Consulting
Bank may act as a municipal finance advisor. OCC Interpretive Letter 122 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,203, 1979 WL 25441, 1979 LEXIS 11 (August 1, 1979).

Municipal Leases and Installment Purchase Contracts - Underwriting the Sale of
Bank may underwrite the sale of municipal leases and installment purchase contracts. OCC Interpretive Letter 250 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,414, 1982 WL 54155, 1982 LEXIS 4 (October 6, 1982).

Municipal Parking Lots
Bank may own a municipal parking lot. Expenditures to acquire represent a business expense to be charged off and not an equity investment. 12 C.F.R. 7.1000.

Municipal Securities Dealers
Bank may act as a municipal securities dealer. 15 U.S.C.A. 78c(a)(30)(B); 12 C.F.R. 10.1-10.41.

Mutual Fund Shares
Bank may purchase for its own account shares of investment companies provided that the portfolios of such companies consist solely of obligations which are eligible for investment by the bank. Section 33 of the Illinois Banking Act [205 ILCS 5/33]. Shares of investment companies whose portfolios contain investments which are subject to the limits of 12 U.S.C. 24 or 12 U.S.C. 84 may only be held by a national bank in an amount not in excess of 10% of bank capital and surplus. OCC Banking Circular 220, Fed. Banking L. Rep. (CCH) ¶49,102, 1986 WL 181421 (November 21, 1986).

Mutual Fund Shares - Purchase and Sale of
Bank may purchase or sell shares in mutual funds as agent without recourse upon a customer's order. OCC Interpretive Letter 363 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,533, 1986 WL 85092, 1986 LEXIS 6 (May 23, 1986).

National Housing Partnerships
Bank may invest in partnerships, limited partnerships, or joint ventures formed pursuant to sections 907(a) or 907(c) of the Housing and Urban Development Act of 1968, the purpose of such partnerships being to provide low and moderate income housing. 12 U.S.C. 24(Seventh); OCC Banking Circular 21 [1966-1973 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶95,264, 1970 WL 12099 (January 14, 1970); Banking Circular 21, Supp. 1, 1973 WL 20885 (January 29, 1973); Banking Circular 21, Supp. 2, 1973 WL 20886 (November 30, 1973). See also Section 5(21) of the Illinois Banking Act [205 ILCS 5/5(21)]; OBRE Interpretive Letter 89-16 (December 28, 1989).

Net Lease Agreements
Bank may offer a residential Net lease home finance product to meet the needs of its customers who adhere to the principals of Islam. OCC Interpretive Letter 806 dated October 17, 1997.

NOW Accounts
Bank may establish NOW accounts. 12 U.S.C. 1832(a).

Nursing Homes - Banking Services
Bank may establish a banking facility at senior citizen's or long term care facility and is not required to file a Notice of Intent to Branch with the Commissioner. Section 44.1 of the Illinois Banking Act [205 ILCS 5/44.1]; OBRE Interpretive Letter 92-03 (April 24, 1992); OBRE Interpretive Letter 94-04 (March 23, 1994).

Obligations of the United States - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, underwrite, and hold without limitation bonds which are indirect obligations of the United States. OCC Interpretive Letter 90 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,165, 1979 WL 2544, 1979 LEXIS 45 (April 30, 1979).

Open Accounts
Bank may purchase open accounts. 12 C.F.R. 7.1020.

Operating Subsidiaries
Bank may engage in banking business by means of operating subsidiary corporations. To qualify as an operating subsidiary, the parent bank must own at least 80% of the subsidiary's voting stock. 12 C.F.R. 5.34. See also OCC-IL-668 (October 14, 1994), OCC-IL-666 (July 11, 1994). See also Section 5(12)(c) of the Illinois Banking Act [205 ILCS 5/5(12)(c)].

Options and Futures - Agricultural
Bank's operating subsidiary may act as futures commission merchant for agricultural futures transactions for bank customers, in connection with hedging activities connected to loans from the bank to the customers. OCC Interpretive Letter dated June 19, 1986, 1986 WL 143994. See also OCC Interpretive Letter 624 (June 30, 1993).

OREO for Mortgages on Other Property
Bank may dispose of OREO in exchange for mortgages on unimproved real estate. OCC Interpretive Letter dated June 4, 1986, 1986 WL 143934.

Original Issue Discount Municipal Bonds - Purchase and Holding of
Bank may purchase and hold original issue discount municipal bonds up to 10% of capital and surplus, subject to certain conditions. OCC Banking Bulletin 85-15 [1984-1985 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶86,305 (July 8, 1985).

Other Real Estate Owned
Other real estate owned by a state bank is subject to the ten-year holding limitation of Section 5(9) of the Illinois Banking Act [205 ILCS 5/5(9)].

Other Real Estate Owned - Exchange or Disposition of
Bank may dispose of OREO in exchange for mortgages on unimproved real estate. OCC Interpretive Letter dated June 4, 1986, 1986 WL 143934.

Other Real Estate Owned - Selling of with Bank Financing
Bank may provide financing for the sale of its OREO. OCC Interpretive Letter dated July 30, 1986, 1986 WL 143914.

Parking Lots
Bank may purchase real estate for use as employee parking lot. OBRE Interpretive Letter 93-09 (July 2, 1993).

Participations
Bank may sell participations in transactions similar to standby letters of credit with certain exceptions. OCC Interpretive Letter 681 (August 2, 1995).

Participations in Equipment Lease Financing Receivable
Bank may purchase a participation interest of less than 100% in an equipment lease financing receivable and such purchase would not be a participation in a partnership. OCC Interpretive Letter 374 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,544, 1986 WL 85081, 1986 LEXIS 18 (December 4, 1986).

Participations in Small Business Administration Guaranteed Loans
Bank may purchase participations in SBA guaranteed loans, subject to certain conditions and limitations. OCC Interpretive Letter 350 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,520, 1985 WL 73144, 1985 LEXIS 26 (September 19, 1985).

Partnership Arrangements to Finance Leveraged Buy-Outs
Bank may establish an operating subsidiary to form a partnership with an affiliate of an investment bank to finance short-term commercial loans, leveraged buy-outs and recapitalizations. OCC Interpretive Letter 517 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,228, 1990 WL 364903, 1990 LEXIS 40 (August 16, 1990) .

Pass-Through Participation Certificates - Purchase of
Bank may purchase pass-through participation certificates that represent interests in pools of FHA-insured Title I property improvement loans. OCC Interpretive Letter 579 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,349, 1992 WL 266690, 1992 LEXIS 16 (March 24, 1992).

Payment-in-Kind Certificates
Bank may purchase P-I-K certificates as an agent or intermediary for its customers but may not purchase them as principal even if the purchase is intended to reduce the P-I-K certificates to cash for customers. Investment Securities Letter 34 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,040, 1989 WL 303735.

Payments Intermediary
Bank operating subsidiaries may facilitate the collection of commissions from insurance underwriters and disburse these commissions to both the various client insurance agencies and the agencies' individual agents. OCC Interpretive Letter 653 (December 22, 1994).

Payroll Issuer
Bank may act as payroll issuer for its customers. 12 C.F.R. 7.1011.

Payroll Processor
Bank may acquire minority interest in a payroll processor. OCC Interpretive Letter 771 (February 24, 1997).

Payment Up Front Fast ("PUFF") Program
Bank may establish a program marketed through an unaffiliated freight forwarding firm which enables exporters to obtain advance payment for goods sold to an overseas buyer. OCC No Objection Letter 89-03b [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,060, 1989 WL 303751, 1989 LEXIS 72 (June 29, 1989).

Performance Note Loans
Bank may purchase performance note loans.  OCC Interpretive Letter 834 (July 8, 1998).

Pledging Assets
Bank may pledge investment securities to secure its borrowings, within limits imposed by the need to maintain adequate liquidity. Section 5(7)(a) of the Illinois Banking Act [205 ILCS 5/5(7)(a)]; OCC Interpretive Letter dated December 16, 1987, 1987 WL 149807.

Pledging Assets to Secure Non-Public Deposits
State bank may pledge assets to secure private deposits to the same extent as Illinois savings banks or federal savings associations.  OBRE Interpretive Letter 98-12 (September 8, 1998)

Pledging Assets to Secure Public Deposits
Bank may pledge assets to secure public deposits. Section 5(7)(c) and (d) of the Illinois Banking Act [205 ILCS 5/5(7)(c) and (d)]; OBRE Interpretive Letter 91-06 (March 14, 1991); OBRE Interpretive Letter 91-04 (February 26, 1991). See also 12 U.S.C. 90; 25 U.S.C. 162a.

Pledging Assets to Secure Trust Funds on Deposit
Bank must pledge assets to secure trust funds on deposit that are awaiting investment or distribution, but the bank may not pledge assets to secure trust funds deposited for investment. Section 5(7)(g) of the Illinois Banking Act [205 ILCS 5/5(7)(g)]. See also OCC Interpretive Letter 453 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,677, 1988 WL 284821, 1988 LEXIS 105 (October 20, 1988).

Political Contributions
State bank may make political contributions or expenditures to, or on behalf of, state and local candidates or political committees. Bank may also make loans to federal, state, and local candidates or campaign committees. Federal law [2 U.S.C. 441(b)] prohibits bank from making political contributions to federal candidates or national committees in a federal election. OBRE Policies, Procedures and Examination Guideline 2007.

Postal Service
Bank may operate and receive income from a postal substation on its premises. 12 C.F.R. 7.1010.

Power of Attorney
Trust department of bank and its officers may act under a power of attorney that encompasses property and financial matters. OBRE Interpretive Letter 91-35 (December 23, 1991).

Preparing Income Tax Returns
Bank may assist in the preparation of its customers' tax returns, either gratuitously or for a reasonable fee, but may not serve as an expert tax consultant. OBRE Interpretive Letter 97-01 (January 21, 1997). See also 12 C.F.R. 7.1008.

Printing
Bank may acquire a printing company to provide bank printing and related design services to the Bank as well as third parties. OCC Interpretive Letter 811 (December 18, 1997).

Private Placement of Asset-Backed Securities and Mortgage-Related Products
Bank may privately place mortgage-backed pass-through certificates representing an interest in a pool of first and second mortgages. OCC Interpretive Letter 194 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,275, 1981 WL 57800, 1981 LEXIS 52 (May 29, 1981); OCC Interpretive Letter 25, 1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,100, 1978 WL 21869, 1978 LEXIS 41 (February 14, 1978).

Private Placement of Debt and Equity Securities
Bank's operating subsidiary may, as agent for the bank's customers, conduct private placement of debt and equity securities. OCC Interpretive Letter 463 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,687, 1988 WL 284832, 1988 LEXIS 120 (December 27, 1988).

Private Placement of Equity Investments in Real Estate Development
Bank and its wholly-owned operating subsidiary may engage in private placement of equity interests in real estate to finance a development project. OCC Interpretive Letter 271 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,435, 1983 WL 54156, 1983 LEXIS 5 (September 21, 1983).

Private Placement of Securities
Bank may participate in the private placement of investment securities. OCC Interpretive Letter 32 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,107, 1977 WL 23310, 1977 LEXIS 11 (December 9, 1977).

Promissory Notes Secured by Lien on Improved Real Estate
Bank may invest in promissory notes secured by a first lien on improved real estate (offered and sold pursuant to section 4(5) of the Securities Act of 1933 (15 U.S.C. 77d(5)). 12 U.S.C. 24(Seventh).

Promotional and Advertising Materials
Bank may sell small, low cost items with bank logo for promotional and advertising purposes. OCC Interpretive Letter 690 (October 2, 1995).

Property
Bank operating subsidiary may hold property acquired by the bank through foreclosure or otherwise in good faith to compromise a doubtful claim, or in the ordinary course of collecting a debt previously contracted. Section 5(12)(a) of the Illinois Banking Act [205 ILCS 5/5(12)(a)]; OBRE Rule titled "Administration of Assets Obtained in Collection of a Debt" [Illinois Administrative Code, Title 38, Part 354]. See also 12 C.F.R. 5.34(e)(2)(ii)(A).

Property Management Services
Bank may employ investment advisors to provide investment advice and property management services. OCC Trust Interpretation 215 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,026, 1989 WL 303729, 1989 LEXIS 42 (May 11, 1989).

Public Depository
Bank may be a depository of public money. Section 5(7)(c) and (d) of the Illinois Banking Act [205 ILCS 5/5(7)(c) and (d)]; 12 U.S.C. 90, 265.

Public Housing Agency Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite without limitation obligations of a public housing agency (as defined in the United States Housing Act of 1937, as amended [42 U.S.C.A. 1437 et seq.]) as are secured (1) by an agreement between the public housing agency and the Secretary of Housing and Urban Development, (2) by a pledge of annual contributions, or (3) by a pledge of annual contributions and a loan between the public housing agency and the Secretary. 12 U.S.C. 24(Seventh).

Public Purpose Corporation Stock
Bank may invest in stock of a public purpose corporation, either for-profit or nonprofit, to carry out activities to benefit low-and moderate-income areas and residents or small businesses. Section 5(21) of the Illinois Banking Act [205 ILCS 5/5(21)]; OCC Banking Bulletin 92-37, Fed. Banking L. Rep. (CCH) ¶59,349 and ¶89,065, 1992 WL 373848 (July 8, 1992). See also OBRE Interpretive Letter 89-16 (December 28, 1989).

Public Facilities
Bank may purchase or construct a municipal building and, as holder of legal title, lease it to a public authority having resources sufficient to make rental payments. OBRE Interpretive Letter 93-27 (December 15, 1993); 12 C.F.R. 7.1000.

Real Estate Asset Management Services
Bank's operating subsidiary may furnish real estate asset management and advisory services to other financial institutions. OCC Interpretive Letter 389 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,613, 1987 WL 154121, 1987 LEXIS 24 (July 7, 1987).

Real Estate Consulting Via Subsidiary
Bank's operating subsidiary may act as finder in locating, analyzing and making recommendations regarding the purchase of property and may make recommendations concerning the sale of property, but the bank may not act as broker in performing these activities. OCC Interpretive Letter 238 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,402, 1982 WL 54143, 1982 LEXIS 16 (February 9, 1982).

Real Estate Development
State bank may engage in real estate development activities or projects, subject to the same restrictions that apply to insured savings associations. Bank's real estate development authority may have to be conducted through a subsidiary with the approval of the FDIC. OBRE Interpretive Letter 98-10 (September 8, 1998)

Real Estate Loans
Bank can make, arrange, purchase or sell loans secured by liens on real estate. Section 3 of the Illinois Banking Act {205 ILCS 5/3]; 12 U.S.C. 371(a); 12 C.F.R. 34.1(a).

Real Estate Loans Via Subsidiary
Bank's operating subsidiary may make commercial real estate loans, including construction and development loans, as originator or participant. Section 5(12)(c) of the Illinois Banking Act [205 ILCS 5/5(12)(c)]. See also OCC Interpretive Letter 389 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,613, 1987 WL 154121, 1987 LEXIS 24 (July 7, 1987).

Real Estate - Purchase of to Secure Previously Contracted Debt
Bank may purchase real property in order to protect a partial interest or title that was acquired to secure previously contracted debt, but bank may not enter into a joint venture to operate such property. OCC Interpretive Letter 12 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,087, 1977 WL 23307, 1977 LEXIS 92 (December 7, 1977). See also OBRE Interpretive Letter 90-20 (October 12, 1990).

Real Estate - Residence for Bank Officer
Bank may own real property that is to be used as a residence for a bank officer when working out of town, as long as I.R.S. allows the expense as a business deduction for the bank. OCC Interpretive Letter No. 263 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,427, 1983 WL 54150 (October 13, 1983). See also OBRE Interpretive Letter 91-33 (December 11, 1991); OBRE Interpretive Letter 95-01 (March 2, 1995).

Real Estate Swaps
Bank may exchange or "trade" OREO for other property provided the transaction is undertaken to substantially reduce or avoid potential loss on OREO property. OCC Interpretive Letter 349 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) 85,519, 1985 WL 73143, 1985 LEXIS 25 (September 12, 1985). See also OBRE Interpretive Letter 93-07.1 (July 2, 1993) (State bank may acquire real estate to swap for real estate to be used as bank premises).

Real Estate Tax Lien Certificates
Bank may purchase real estate tax lien certificates if not considered an interest in real property under state law. OCC Interpretive Letter 717 (March 22, 1996).

Realtors - Finder for
Bank may act as finder by introducing potential buyers to sellers of real estate. OCC Interpretive Letter dated August 20, 1987, 1987 WL 149774.

Remittance Processing
Bank may pick up deposits from post office boxes through an operating subsidiary. OCC Interpretive Letter 635 (July 23, 1993).

Residences of Bank Personnel
Bank may purchase and hold residential real estate for benefit of bank personnel, subject to certain limitations. OBRE Interpretive Letter 91-33 (December 11, 1991); OBRE Interpretive Letter 95-01 (March 2, 1995)

Reverse Mortgage Loans
Bank may engage in making "reverse mortgage" loans, which are extended on the basis of existing equity in a homestead property. Section 5a of the Illinois Banking Act [205 ILCS 5/5a]. See also Section 6.1 of the Illinois Banking Act [205 ILCS 5/6.1] for provisions specifically applicable to reverse mortgage loans made to senior citizens.

Safe-Deposit Corporations
Bank may invest in the capital stock of a corporation organized under state law to conduct a safe-deposit business, provided that the investment does not exceed 15% of the unimpaired, paid-in capital stock of the bank, and 15% of its unimpaired surplus. 12 U.S.C. 24(Seventh).

Sale of Loans to FHLMC
Bank may sell loans to FHLMC. 12 U.S.C. 1454(a).

Savings Bonds
Bank operating subsidiaries may sell savings bonds. 12 C.F.R. 5.34(e)(2)(ii)(D).

School Savings Program
Bank may participate in school thrift or savings plan and may accept deposits at such school through the bank's own employees or employees of the school acting as collecting agent for the bank. Section 44 of the Illinois Banking Act [205 ILCS 5/44]. See also OCC No Objection Letter 89-03a [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,015, 1989 WL 303769, 1989 LEXIS 32 (April 21, 1989).

Securities Brokerage Activities
State bank may offer full service securities brokerage services through a wholly-owned subsidiary. OBRE Declaratory Ruling 320-90-1; OBRE Declaratory Ruling 320-91-1. Bank may engage in securities brokerage activities using dual employees. OCC Interpretive Letter 630 (May 11, 1993); OCC Interpretive Letter 760 (November 14, 1996); OCC Interpretive Letter 680 (July 26, 1995); OCC Interpretive Letter 656 (March 13, 1995); OCC Interpretive Letter 648 (May 4, 1994); OCC Interpretive Letter 647 (April 15, 1994); OCC Interpretive Letter 629 (July 2, 1993); OCC Interpretive Letter 625 (July 1, 1993); OCC Interpretive Letter 622 (April 9, 1993).

Securities Guaranteed by Federal Agricultural Mortgage Board - Purchase of, Dealing in. and Underwriting of
Bank may purchase, hold, deal in, and underwrite securities fully secured by the Federal Agricultural Mortgage Board without limitation. OCC Interpretive Letter 512 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,214, 1990 WL 364898, 1990 LEXIS 15 (July 9, 1990). See also OBRE Interpretive Letter 88-06 (October 11, 1988).

Securities Lending
Bank may lend U.S. government securities to another bank, for the second bank to pledge to secure state deposits, subject to the bank's legal lending limit. OCC Interpretive Letter dated September 21, 1981, 1981 WL 50475; OCC Interpretive Letter 376 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,6000, 1986 WL 89629, 1986 LEXIS 21 (October 25, 1986); OCC Banking Circular 196 [1984-1985 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶86,248 (May 7, 1985).

Security Services
Bank's operating subsidiary which provides security and guard services for the bank may also perform such services for affiliated banks and non-banks owned by the parent holding company. OCC Interpretive Letter 398 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,622, 1987 WL 149897, 1987 LEXIS 45 (September 28, 1987).

Security Monitoring Services
Bank may provide security monitoring services to other financial institutions. OCC Interpretive Letter dated June 6, 1985, 1985 WL 143955.

Selling OREO with Bank Financing
Bank may provide financing for the sale of its OREO. OCC Interpretive Letter dated July 30, 1986, 1986 WL 143914.

Service of Process - Agent for
Bank may serve as agent for sole purpose of accepting service of process in any action arising from private placement of securities. OCC Interpretive Letter dated November 4, 1977, Fed. Banking L. Rep. (CCH) ¶85,074.

Shared Appreciation Mortgage Loans
Bank may make a shared appreciation mortgage loan to a developer for the conversion of residential property into condominium units and receive a fixed amount or percentage of the sales price of each unit sold; and, the bank may finance the acquisition or improvement of real property on which the borrower will operate its business. OCC Interpretive Letter 244 [1983-1984 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,408, 1982 WL 54149, 1982 LEXIS 18 (January 26, 1982). See also OCC Interpretive Letter 620 (July 15, 1992).

Sharing Premises
Bank may share premises with another bank. 12 C.F.R. 7.3001.

Small Business Administration Guaranteed Pool Certificates - Purchase of, Dealing in, and Underwriting of
Bank may purchase, underwrite, deal in, and hold for its own account SBA-guaranteed pool certificates without limitation. OCC Interpretive Letter 373 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,543, 1986 WL 85080, 1986 LEXIS 17 (November 13, 1986).

Small Business Administration Loans - Purchase and Sale of
Bank may purchase and sell for its own account SBA guaranteed portions of loans as part of the SBA's secondary market program. OCC Interpretive Letter 141 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,222, 1980 WL 48447, 1980 LEXIS 28 (May 19, 1980).

Small Business Investment Company Stock
Bank may purchase small business investment company stock to the extent that the aggregate of all shares of such stock does not exceed 5% or the bank's capital and surplus or result in the bank holding 50% or more of any class of equity securities with actual or potential voting rights issued by a particular investment company. The bank's receipt and retention of a dividend in the form of stock of a corporate borrower of the small business investment corporation is not a purchase of stock within the meaning of 12 U.S.C. 24. OBRE Interpretive Letter 86-02 (October 24, 1986); OBRE Interpretive Letter 93-30 (December 21, 1993); 15 U.S.C. 682(b); 12 C.F.R. 7.1015. See also OCC Interpretive Letter 617 (March 4, 1993) and OCC Interpretive Letter 832 (June 18, 1998).

Software Development
Bank may establish operating subsidiaries to engage through a joint venture in the development and distribution of home banking and financial management software. OCC Interpretive Letter 677 (June 28, 1995). See also OCC Interpretive Letter 732 (May 10, 1996) and OCC Interpretive Letter 756 (November 5, 1996).

Split Dollar Life Insurance
Bank may purchase "split dollar" life insurance on an officer or director, under which the bank transfers the benefit portion of the policy to the officer or director upon retirement or resignation, while retaining ownership of a portion of the policy sufficient to recover the bank's investment in the policy. OCC Interpretive Letter 429 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,653, 1988 WL 284813, 1988 LEXIS 32 (May 19, 1988); OCC Banking Circular 249, 4 Fed. Banking L. Rep. (CCH) ¶49,162 (May 9, 1991).

Standby Letters of Credit - Generally
Bank may issue a standby letter of credit subject to conditions and limitations. Section 34(5) of the Illinois Banking Act [205 ILCS 5/34(5)]. See also OCC Interpretive Letter dated September 5, 1985, 1985 WL 73110; OCC Interpretive Letter 57 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,132, 1978 WL 21850, 1978 LEXIS 10 (October 5, 1978).

Standby Letters of Credit - Mortgage-Backed Securities
Bank may issue standby letter of credit in connection with its sale of mortgage-backed pass-through certificates. OCC Interpretive Letter 145 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,226, 1990 WL 42018, 1990 LEXIS 43 (July 9, 1980); OCC Interpretive Letter 189 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,270, 1981 WL 57796, 1981 LEXIS 53 (May 11, 1981); OCC Interpretive Letter 132 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,213, 1980 WL 42040, 1980 LEXIS 47 (February 1, 1980).

Standby Letters of Credit - Municipal Bond Insurance
Bank's operating subsidiary may offer standby letters of credit to support municipal bond issues in the form of municipal bond insurance. OCC Interpretive Letter 338 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,508, 1985 WL 73130, 1985 LEXIS 23 (May 2, 1985).

Standby Letters of Credit - Private Placement Advisory Services
Bank may issue standby letter of credit in connection with its private placement advisory services to support an industrial revenue bond issue. OCC Interpretive Letter 212 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,293, 1981 WL 50490, 1981 LEXIS 27 (July 2, 1981).

Standby Letters of Credit - Residential Mortgage Revenue Bonds
Bank may issue a standby letter of credit to support a residential mortgage revenue bond issuance. OCC Interpretive Letter 144 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,225, 1980 WL 42017, 1980 LEXIS 45 (June 10, 1980).

State and Political Subdivision Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, underwrite and hold without limitation general obligations of any State or of any political subdivision thereof. 12 U.S.C. 24(Seventh); 12 C.F.R. 1; OCC Interpretive Letter 65 [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,140, 1978 WL 21856, 1978 LEXIS 10 (October 5, 1978). See also Section 35(4) of the Illinois Banking Act [205 ILCS 5/35(4)].

State Housing Corporations
Bank may invest in shares of stock issued by any State housing corporation incorporated in the State in which the bank is located to the extent such investments do not exceed 5% of the bank's unimpaired, paid-in capital stock, plus 5% of its unimpaired surplus. 12 U.S.C. 24(Seventh).

State Issued Obligations for Housing, University, or Dormitory Purposes - Purchase of,
Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite obligations issued by any State or political subdivision for housing, university, or dormitory purposes in an amount up to 10% of the bank's capital and surplus. 12 U.S.C. 24(Seventh); 12 C.F.R. 1.3(d), 1.7.

Stock Acquired in Lieu of DPC
Bank may acquire newly issued stock in other banks in settlement of debts previously contracted so long as stock is acquired primarily as a means of preventing or limiting loan losses. OCC Interpretive Letter 444 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,668, 1988 WL 284843, 1988 LEXIS 71 (August 11, 1988).

Stock Acquired As Debt Satisfaction
Bank may acquire stock in satisfaction of debts previously contracted, as this acquisition is incidental to the business of banking, subject to 5-year holding limitation. OCC Interpretive Letter 151 [1981-1982 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,232, 1980 WL 42023 (June 27, 1980). See also OBRE Interpretive Letter 97-02 (March 11, 1997).

Stock Exchange - Membership in
Bank's operating subsidiary may purchase a seat on the American Stock Exchange and become a member of the exchange for the purpose of purchasing and selling U.S. Treasury securities, so long as the exchange confirms that the liability of the operating subsidiary will be limited to its capital. OCC Interpretive Letter dated May 21, 1986, 1986 WL 143947.

Stock in Company Affiliated with Captive Insurer
Bank may purchase shares of stock in a company affiliated with an industry captive insurance company when such purchase is a condition precedent to obtaining insurance from the captive. OCC Interpretive Letter No. 554 [1991-1992 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,301, 1990 WL 364931 (May 7, 1990).

Stock Warrants (Equity Kickers)
Bank may establish an operating subsidiary that will enter into two tandem limited partnerships, one of which will make commercial loans in connection with highly leveraged transactions, while the other will hold stock warrants as "equity kickers" in connection with such loans, and the bank may provide investment advice to the limited partnerships. OCC Interpretive Letter 517 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,228, 1990 WL 364903, 1990 LEXIS 40 (August 16, 1990).

Stored Value Systems
Bank may acquire a minority interest in a limited liability company providing stored value systems. OCC Interpretive Letter 737 (August 19, 1996).

Student Loan Marketing Association Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite without limitation obligations or other instruments or securities of the Student Loan Marketing Association. 12 U.S.C. 24(Seventh); 12 U.S.C. 84(c)(10). See also OBRE Interpretive Letter 92-05 (May 14, 1992); OBRE Interpretive Letter 87-02 (January 27, 1987).

Surety Bonds as Pledge for Trust Funds on Deposit
Bank may substitute surety bond for required pledge of securities against trust funds deposited on the commercial side of bank. OCC Interpretive Letter 679 (July 1, 1994). See also 205 ILCS 620/2-8.

Swap Activities
Subject to limitations, bank may act as principal in matched and unmatched commodity price index, interest rate, and currency swaps. OCC No Objection Letter 90-1 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,095, 1990 WL 352127, 1990 LEXIS 6 (February 16, 1990). See also OCC Interpretive Letter 652 (September 13, 1994); OCC Interpretive Letter 643 (July 1, 1992).

Sweeps
Bank's operating subsidiary may provide a sweep arrangement in which it would, at the request of a customer, invest proceeds from the sale of securities in a money market fund and withdraw fund monies to purchase securities for the customer. OCC Interpretive Letter 326 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,496, 1985 WL 73120, 1985 LEXIS 20 (January 17, 1985).

Tax Auditing Representation
Bank may engage in selling a tax auditing representation service to its customers, so long as the bank does not serve as an expert tax consultant. OCC Interpretive Letter 437 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,661, 1988 WL 284811, 1988 LEXIS 95 (July 27, 1988).

Tax Preparation Services
Bank may assist in the preparation of its customers' tax returns, either gratuitously or for a reasonable fee, but may not serve as an expert tax consultant. OBRE Interpretive Letter 97-01 (January 21, 1997); 12 C.F.R. 7.1008.

T-Bill Futures Market Participation
Bank may participate in T-bill futures markets, subject to conditions outlined in OCC Banking Circular 79. OCC Interpretive Letter dated September 21, 1977, [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,037.

Tennessee Valley Authority Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite bonds, notes and other obligations issued by the Tennessee Valley Authority in an amount up to 10% of the bank's capital and surplus. 12 U.S.C. 24(Seventh); 12 C.F.R. 1.3(d), 1.7.

Title Insurance
Bank may sell title insurance, subject to licensure by the Illinois Department of Financial Institutions. OBRE Interpretive Letter 98-09 (September 8, 1998).

Transfer Agent
Bank may act as transfer agent for corporate debt and equity issues. OCC Trust Interpretation 202 [1989-1990 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,005, 1989 WL 303721, 1989 LEXIS 17 (February 15, 1989).

Travel Agency
Bank may lease excess office space to a travel agency, subject to certain conditions. OCC Interpretive Letter 399 [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,623, 1987 WL 149898, 1987 LEXIS 46 (October 29, 1987); OCC Interpretive Letter 342 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,512, 1985 WL 73134, 1985 LEXIS 16 (May 22, 1985). See also Section 5(22) of the Illinois Banking Act [205 ILCS 5/5(22)] (State bank that owned or operated a travel agency prior to July 1, 1991 is authorized to own or operate a travel agency).

Travel Service Activities
Bank may arrange short trips for travel club members where club is comprised of depositors over age 50 so long as travel service is clearly only a promotional activity on the part of the bank. OCC Interpretive Letter dated April 16, 1986, 1986 WL 144002.

Travel Services
Bank may provide travel related services that are incidental to banking but may not operate a full-scale travel agency. OCC Interpretive Letter dated August 12, 1977, [1978-1979 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,012. See also Section 5(22) of the Illinois Banking Act [205 ILCS 5/5(22)] (State bank that owned or operated a travel agency prior to July 1, 1991 is authorized to own or operate a travel agency).

Travel-Related Company - Contracting with
Bank may enter into a marketing arrangement with an unaffiliated tour operator whereby, in return for a commission, the bank would furnish the tour operator with names and addresses of certain letter introducing the tour operator and its programs. OCC Interpretive Letter 339 [1985-1987 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,509, 1985 WL 73131, 1985 LEXIS 13 (May 16, 1985).

Treasury Stock
Illinois state-chartered bank may purchase and hold shares of its own stock as treasury stock. Section 14(6) of Illinois Banking Act [205 ILCS 5/14(6)]. National bank may purchase or hold shares of its own stock only if necessary to prevent loss upon a debt previously contracted and subject to a six-month time limitation. 12 U.S.C. 83; 12 C.F.R. 7.2019.

Trust Powers
Bank may engage in trust activities, subject to conditions and limitations. Section 3 of the Illinois Banking Act [205 ILCS 5/3]; 12 U.S.C. 92a; 12 C.F.R. 9.1-9.22.

Unit Investment Trusts - Purchase and Sale of
Bank may purchase or sell units in Unit Investment Trusts as agent without recourse upon the order of its customers. OCC Interpretive Letter 363 [1985-1978 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶85,533, 1986 WL 85092, 1986 LEXIS 6 (May 23, 1986).

U.S. Postal Service Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in, and underwrite obligations issued by the United States Postal Service in an amount up to 10% of the bank's capital and surplus. 12 U.S.C. 24(Seventh); 12 C.F.R. 1.3(d), 1.7.

Vault, Lock and ATM Service
Bank may offer vault, lock and ATM services to other financial institutions as correspondent services. OCC Interpretive Letter 508 [1990-1991 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶83,206, 1990 WL 364909, 1990 LEXIS 23 (April 6, 1990).

Vehicle Service Contracts
Bank may sell as agent vehicle service contracts to bank customers financing the purchase or lease of automobiles. OCC Interpretive Letter 671 (July 10, 1995), OCC Interpretive Letter 724 (April 22, 1996).

Veterans Housing Loans
Bank can make certain housing loans to qualified veterans that will be guaranteed. 38 U.S.C. 3702(d).

Warehousing
Bank operating subsidiary may engage in warehousing products, services, and related activities, including associated equipment technology, for the operating subsidiary, its parent bank, and their affiliates. 12 C.F.R. 5.34(e)(2)(ii)(H).

Washington Metropolitan Area Transit Authority Obligations - Purchase of, Dealing in, and Underwriting of
Bank may purchase, deal in and underwrite without limitation obligations of the Washington Metropolitan Area Transit Authority which are guaranteed by the Secretary of Transportation under Section 9 of the National Capital Transportation Act of 1969 [D.C. Code 1-2458]. 12 U.S.C. 24(Seventh).