Fair Housing Home Loan Data System

Federal RegisterMay 20, 1994

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DEPARTMENT OF THE TREASURY

Office of the Comptroller of the Currency

12 CFR Part 27

[Docket No. 94-09]

RIN 1557-AB33

Fair Housing Home Loan Data System

AGENCY: Office of the Comptroller of the Currency, Treasury.

ACTION: Final rule.

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SUMMARY: The Office of the Comptroller of the Currency (OCC) is issuing

a final rule amending its Fair Housing Home Loan Data System (FHHLDS).

This final rule enhances the OCC's ability to use data collected under

the Home Mortgage Disclosure Act (HMDA) in fair lending examinations

and reduces recordkeeping requirements on national banks that are

currently required to maintain duplicative information under both the

FHHLDS and the HMDA. In order to relieve duplicative recordkeeping for

those national banks, this final rule replaces the current FHHLDS

monthly recordkeeping requirement with the HMDA Loan/Application

Registers already maintained by national banks, which will be required

to be updated on a quarterly basis. In order to improve the OCC's

ability to use HMDA data in fair lending examinations, this final rule

requires that all national banks subject to the HMDA, including those

banks not subject to the FHHLDS, maintain information on the HMDA Loan/

Application Registers on a quarterly basis. National banks that are not

subject to the HMDA requirements will continue to be subject to the

original FHHLDS recordkeeping requirement, which will be updated

quarterly under this final rule. The intended effect of this final rule

is to improve the OCC's supervision of national banks while also

reducing a duplicative recordkeeping burden on affected national banks.

EFFECTIVE DATE: June 20, 1994.

FOR FURTHER INFORMATION CONTACT: Larry Riedman, Fair Lending

Specialist, Compliance Management Division, (202) 874-4446; or F. John

Podvin, Jr., Attorney, Bank Operations and Assets Division, (202) 874-

4460, Office of the Comptroller of the Currency, Washington, DC 20219.

SUPPLEMENTARY INFORMATION: The OCC is amending 12 CFR part 27,

pursuant to 12 U.S.C. 93a, to improve its ability to use HMDA data

in fair lending examinations of national banks and reduce burden on

national banks. The final rule requires that HMDA Loan/Application

Registers be updated quarterly, requires the reason(s) for loan

denial be indicated on the HMDA Loan/Application Registers and

relieves the requirement to maintain duplicative records for those

national banks that currently maintain records under both the

FHHLDS and the HMDA, 12 U.S.C. 2801 et seq.

Background

On November 2, 1979, the OCC published a final rule (1979 final

rule) in the Federal Register (44 FR 63084), which implemented 12 CFR

part 27. The 1979 final rule provided a basis for a more effective fair

housing monitoring program for home loans. The 1979 final rule

established new recordkeeping requirements and a data collection system

for monitoring national bank compliance with the Fair Housing Act

(Title VIII of the Civil Rights Act of 1968), 42 U.S.C. 3601 et seq.

and the Equal Credit Opportunity Act, 15 U.S.C. 1691 et seq.

In August 1989, the Financial Institutions Reform, Recovery and

Enforcement Act of 1989 (FIRREA), section 1211, Public Law 101-73, 103

Stat. 183 (12 U.S.C. 2803) amended the HMDA. On December 15, 1989, the

Federal Reserve Board published a final rule (FRB final rule) in the

Federal Register (54 FR 51356). The FRB final rule implemented a

revised version of 12 CFR part 203 (Regulation C), which is the

implementing regulation for the HMDA. Under the FRB final rule, certain

national banks and their majority-owned mortgage banking subsidiaries

must maintain individual loan application registers and forward them

annually to the appropriate OCC office.

In response to FIRREA and the FRB final rule, the Office of Thrift

Supervision (OTS) and the Federal Deposit Insurance Corporation (FDIC)

amended their regulations concerning home loan activity to make them

similar to Regulation C.

OCC Proposed Rule

On May 10, 1993, the OCC issued a notice of proposed rulemaking,

pursuant to 12 U.S.C. 93a, to amend the FHHLDS. See 58 FR 27484. In its

proposed rule, the OCC recognized that national banks subject to the

recordkeeping requirements of both the FHHLDS and the HMDA were

required to maintain duplicative information on home loan activity. The

OCC proposal sought to relieve the duplicative recordkeeping burden on

these banks without affecting banks that are not subject to the HMDA,

but currently are subject to the monthly recordkeeping requirement in

the FHHLDS.

In its proposed rule, the OCC sought to amend the FHHLDS to relieve

the duplicative recordkeeping requirement for banks subject to both

FHHLDS and HMDA by replacing the recordkeeping requirement on monthly

home loan activity, currently located at Sec. 27.3(a), with the

existing requirement in the HMDA and Regulation C. Regulation C

generally requires that national banks (and their majority-owned

mortgage banking subsidiaries) with an office or branch located in a

metropolitan statistical area (MSA) or primary MSA, as defined by the

Office of Management and Budget (OMB), and with total assets greater

than $10 million as of December 31 of the preceding calendar year,

maintain information on home loan activity.

Under the proposal, national banks subject to the HMDA would

maintain the information in a format similar to that prescribed under

Regulation C (Loan/Application Register or LAR), except that (1) if a

loan is denied, the reason(s) for denial are required to be entered on

the Loan/Application Register; and (2) all the required information is

entered on the Loan/Application Register within 30 calendar days after

final disposition of the loan application.

The OCC proposal retained the existing monthly recordkeeping

requirements in the FHHLDS for national banks that are not subject to

the HMDA and Regulation C. The OCC proposal also retained the remaining

provisions of the FHHLDS, which authorize the Comptroller to use his or

her discretion in requiring national banks to maintain a Fair Housing

Inquiry/Application Log or to complete Home Loan Data Submission Forms

if the Comptroller has reason to believe that a national bank is

engaging in discriminatory practices. Also, several clarifying

amendments to Sec. 27.7 were proposed. These changes made Sec. 27.7

conform with the proposed amendments to the recordkeeping requirements

in Sec. 27.3(a). The proposal also stated that the OCC is studying the

FHHLDS to determine what data are most effective in identifying

discrimination in home lending, to identify the most effective and

least burdensome method for collecting home loan data, and to develop

an improved statistical model that will enhance its ability to analyze

home loan data.

The OCC invited public comment on any aspect of the proposed rule

for a 60 day period ending on July 9, 1993. The OCC specifically sought

comment on the issue of whether the recordkeeping burden imposed by the

proposal was minimal. The OCC received 44 comment letters from banks,

bank holding companies, trade groups and the OMB. Forty-one commenters

expressed general support for the proposed rule; however, several of

these same commenters objected to specific provisions of the proposal.

Two commenters made recommendations without expressing support for or

opposition to the proposed rule. The OMB did not express support for or

opposition to the proposed rule.

Pursuant to 12 U.S.C. 93a, this final rule revises the proposed

rule based on the 44 comment letters and makes other changes to clarify

the requirements in the proposed rule.

Review of Comments

The following is a discussion of the issues raised by the

commenters, the OCC's responses to those issues, and a summary of

changes made to the proposed rule.

A. Update Requirement

The proposed rule stated that a national bank subject to the HMDA

was required to record all information on the HMDA-LAR within 30

calendar days after the final disposition of the loan application

(i.e., the application is denied, withdrawn, or the loan closes).

Commenters in favor of the 30-day update requirement included both

small and large national banks. Generally, these banks indicated that

they were already updating their LARs within the 30-day time period.

One comment letter from a bank trade association agreed and stated that

the 30-day update requirement would not impose a significant additional

burden on banks.

Commenters opposed to the 30-day update requirement also included

small and large national banks. These commenters suggested that the OCC

extend the 30-day period to various lengths of time, including: 45

days, 60 days, and quarterly. These commenters stated that they would

have to change their current recordkeeping procedures in order to

comply with the 30-day update requirement, resulting in an increase in

recordkeeping burden. Some of the specific problems or concerns cited

by these commenters include the following:

Banks with many branches generally submit home loan data

monthly to a central location for entry onto the bank's central LAR. In

order to meet the 30-day requirement, branches would have to submit the

information bi-weekly.

Some banks do not input the geo-coding information (i.e.,

state, county, MSA and census tract codes) because it is time consuming

and can be managed better by automated systems operated by third-party

specialists. Because this process is expensive, it is done on a

quarterly basis. These banks also stated that it would be very

expensive to bring this process in-house.

Banks will have a problem assuring data accuracy on a 30

day, loan-by-loan basis. A longer updating time frame will allow more

time for editing and correcting the data.

A group of commenters recommended that the OCC consider

the impact the 30-day update requirement may have on small national

banks that do not have automated reporting systems.

In response to these comments and in the interest of minimizing

recordkeeping burden on national banks, the OCC replaced the 30-day

update requirement with a quarterly update requirement in the final

rule. The final rule states that a national bank subject to the HMDA is

required to record all information on the HMDA-LAR within 30 calendar

days after the end of each calendar quarter.

The OCC also changed the update requirement for non-HMDA banks that

are required to maintain the FHHLDS's monthly home loan activity

report. Under the proposed rule, non-HMDA banks that receive 50 or more

home loan applications a year were required to maintain home loan data

in a report that was updated monthly, within 10 working days after the

close of the month, in a format consistent with the bank's

recordkeeping procedures. Under this final rule, that report is updated

quarterly, within 30 calendar days after the end of each calendar

quarter, in a format consistent with the bank's recordkeeping

procedures. This change will make both HMDA banks and non-HMDA banks

subject to the same updating requirement.

B. Reasons for Denial

Under the proposed rule, a national bank subject to the HMDA was

required to maintain the reason(s) for denying a loan application.

The commenters in favor of the reasons for denial requirements

generally stated that they were already voluntarily providing the

reason(s) for denial. Several commenters also stated that it was a good

idea to require the reasons for denial in order to better monitor the

bank's lending activity and compliance with fair housing statutes.

The commenters opposed to the reason(s) for denial requirement

provided various reasons for their opposition. One commenter stated

that the nine HMDA codes are too limited to fully explain the reason(s)

for the denial and that the true reason(s) for the denial can be found

by examiners in the loan file. Another commenter stated that the FDIC

does not require the reason(s) for denial in its regulation. Finally,

another commenter preferred the treatment under Regulation C, which

states that providing the reason(s) for denial is optional. See 12 CFR

203.4(c).

After considering these comments, the OCC determined that the final

rule will retain the requirement that national banks maintain the

reason(s) for denying a loan application for the following reasons. The

OCC believes that requiring the reason(s) for denial will improve both

the OCC's and national banks' monitoring of lending activity and

compliance with fair housing statutes. The OCC notes that the OTS also

requires the reason(s) for denial in its regulation, codified at 12 CFR

528.6(d)(2)(viii).

Several commenters suggested that the OCC include provisions in the

final rule requiring national banks to use the nine HMDA codes when

entering the reason(s) for denial. Another commenter suggested that the

OCC devise a key of various reason(s) for denial based upon a list used

in adverse action notices under the Equal Credit Opportunity Act. Based

on these comments, the OCC determined that HMDA codes are needed for

consistency. The final rule requires national banks to use the nine

HMDA codes provided in Regulation C.

C. Recordkeeping Burden Comments

In the proposed rule, the OCC specifically requested comments on

the issue of whether the recordkeeping burden imposed by the proposal

was minimal. Commenters stating that burden would be increased under

the proposal were substantially outnumbered by commenters stating that

burden would be decreased.

Many commenters stated generally that the proposal would reduce

recordkeeping burden. Several commenters referred to the reduction in

staff hours and resources used in recording home loan information.

Another commenter stated that those resources could be used in other

areas if the proposal was adopted.

Commenters stating that burden would be increased generally focused

on the 30-day update requirement and the burden associated with

changing procedures to meet the proposed time period. The OCC changed

the 30-day update requirement in the proposed rule to a quarterly

update requirement in the final rule to alleviate the potential burden

increase identified by these commenters.

D. Accuracy of the Data

While the proposed rule was silent on the issue of data accuracy,

several commenters were concerned about this issue. One commenter

stated that currently the bank employed procedures to check the

accuracy of the data annually, just before the bank must report its

HMDA data. The commenter stated that the 30-day update requirement

would require a significant change in the bank's procedures in order to

ensure that the data are accurate. Another commenter suggested that a

bank should only be held to a standard of reasonable diligence and good

faith as to the accuracy of the data prior to the annual filing.

The OCC believes that updating quarterly rather than monthly will

reduce the burden of ensuring the accuracy of the data entered onto the

LAR. The OCC notes that Regulation C already contains a provision

relating to data accuracy. Regulation C provides that an error in

compiling or recording loan data is not a violation of the HMDA or

Regulation C if it was unintentional and occurred despite the

maintenance of procedures reasonably adapted to avoid such errors. See

12 CFR 203.6(b). The OCC believes that this standard is adequate and

does not need to be restated. National banks subject to the HMDA that

do not have this type of procedure in place should develop a procedure

to meet this standard.

E. Compliance Alternatives

Under the proposed rule, national banks subject to the HMDA could

not comply with the monthly recordkeeping requirement by completing the

monthly home loan activity report in Sec. 27.3(a)(2). Similarly, non-

HMDA national banks could not comply with the monthly recordkeeping

requirement by maintaining a HMDA-LAR in accordance with the

requirements in Sec. 27.3(a)(1).

One commenter suggested that all banks be given an alternative to

comply with the FHHLDS monthly recordkeeping requirement by using

either the HMDA-LAR or the monthly home loan activity report. Two other

commenters suggested that non-HMDA banks be allowed to record their

monthly home loan activity in the HMDA-LAR format in order to take

advantage of available on-line automated systems for LAR preparation

rather than requiring them to maintain a handwritten monthly home loan

activity report.

The OCC believes that not all banks should be given a compliance

alternative, particularly in light of the change to a quarterly update

requirement in the final rule. However, the OCC believes that national

banks not subject to HMDA should be allowed to comply with the

quarterly recordkeeping requirement by maintaining either the monthly

home loan activity report or the HMDA-LAR, in accordance with this

final rule. This alternative will allow non-HMDA national banks that

are subject to the FHHLDS to take advantage of available on-line

automated systems for LAR preparation. The final rule reflects this

change.

F. Frequency of Reporting

The proposed rule addressed only maintenance of home loan data and

did not include provisions on the filing or reporting of the data. One

bank was concerned that, while not stated as a purpose of the proposal,

the increased processing and editing of the LAR could be the foundation

for increasing the frequency of filing the HMDA data from the current

annual requirement. According to the commenter, increased filing ran

the risk of presenting an unrealistic snapshot of the bank's lending

performance.

The quarterly recordkeeping requirement in Sec. 27.3(a) is a

records maintenance requirement and not a reporting requirement. The

reporting requirement for the HMDA is located in Regulation C at 12 CFR

203.5(a). Changes in the frequency of reporting or filing HMDA data, if

any, would be made to Regulation C, a FRB regulation.

G. Retroactivity

One commenter recommended that the final rule be promulgated on a

retroactive basis, effective January 1, 1993. The OCC declines to

accept the commenter's recommendation. While the OCC believes that the

final rule reduces recordkeeping burden, certain national banks must be

given time to change their procedures to comply with these

requirements. Therefore, the final rule will become effective June 20,

1994.

H. Differences Between the FHHLDS and HMDA

Five commenters pointed out differences between the FHHLDS and the

HMDA. One commenter submitted two exhibits detailing differences in

coverage and information requirements. Another commenter suggested that

the two systems should be subject to the same reporting standards. A

third commenter suggested that the definition of ``home loan'' be the

same for both regulations. Another commenter suggested that the loans

covered in 12 CFR 202.13(a) should be used as a guide for the FHHLDS.

Finally, one commenter pointed out that the FHHLDS does not have a

mechanism to deal with cases where a mail or telephone applicant for a

loan declines to provide information regarding race or sex. The

commenter pointed out that Regulation C has this type of mechanism.

As noted in the proposed rule, the OCC is studying the FHHLDS to

determine what data are most effective in identifying discrimination in

home lending, to identify the most effective and least burdensome

method for collecting home loan data, and to develop an improved

statistical model that will enhance our ability to analyze home loan

data. The OCC is considering, but chose not to implement these

commenters' suggestions into this final rule because of the necessity

and importance of enhancing the HMDA data and reducing regulatory

burden as soon as possible. However, the issues raised by the

commenters will be considered further in the context of the OCC's

ongoing study of the FHHLDS. After the study is complete, the OCC

expects to publish in the Federal Register a notice of proposed

rulemaking to explain any further proposed changes to the FHHLDS.

I. The OMB Comment

In an official comment, the OMB stated that ``the OCC should revise

12 CFR 27.3(b)(1)(xx) and 12 CFR 27.4(c)(5) so that the race and ethnic

categories in its regulations are consistent with OMB Statistical

Policy Directive No. 15, `Race and Ethnic Standards for Federal

Statistics and Administrative Reporting.''' The effect of the suggested

revisions is to change the way the regulation refers to various racial

and ethnic groups. The OCC determined that the suggested technical

revisions are in keeping with the intent of the proposal. Therefore,

the OCC has adopted OMB's suggested revisions of Secs. 27.3(b)(1)(xx)

and 27.4(c)(5) and has made conforming changes to Appendices II, III,

and IV.

Paperwork Reduction Act

The collection of information contained in this final rule has been

submitted to the Office of Management and Budget (OMB) under control

number 1557-0159 in accordance with the Paperwork Reduction Act of 1980

(44 U.S.C. 3504(h)).

For those banks required to submit Home Loan Data Submission Forms,

pursuant to Sec. 27.7, the reporting burden for the estimated 13 banks

filing reports will average approximately 100 hours annually, varying

by the size and activity of the bank. The recordkeeping burden for the

estimated 3,750 banks maintaining records will average approximately

1.3 hours annually.

Comments concerning the accuracy of these burden estimates and

suggestions for reducing burden should be directed to the Office of the

Comptroller of the Currency, Legislative, Regulatory, and International

Activities, Attention: 1557-0159, 250 E Street SW., Washington, DC

20219, and the Office of Management and Budget, Paperwork Reduction

Project (1557-0159), Washington, DC 20503.

Regulatory Flexibility Act

It is hereby certified that this regulation will not have a

significant economic impact on a substantial number of small entities.

Accordingly, a regulatory flexibility analysis is not required. This

regulation relieves an unnecessary duplicative recordkeeping burden on

banks that are subject to the recordkeeping requirements of both the

FHHLDS and the HMDA.

Executive Order 12866

The OCC has determined that this regulation is not a significant

regulatory action.

List of Subjects in 12 CFR Part 27

Civil rights, Credit, Fair housing, Mortgages, National banks,

Reporting and recordkeeping requirements.

Authority and Issuance

For the reasons set out in the preamble, part 27 of chapter I of

title 12 of the Code of Federal Regulations is amended as set forth

below:

PART 27--FAIR HOUSING HOME LOAN DATA SYSTEM

1. The authority citation for part 27 is revised to read as

follows:

Authority: 5 U.S.C. 301; 12 U.S.C. 1 et seq., 93a, 161, 481, and

1818; 15 U.S.C. 1691 et seq.; 42 U.S.C. 3601 et seq.; 12 CFR part

202.

2. In Sec. 27.3, paragraphs (a) and (b)(1)(xx) are revised to read

as follows:

Sec. 27.3 Recordkeeping requirements.

(a) Quarterly recordkeeping requirement. (1) A bank that is

required to collect data on home loans under part 203 of this title

shall present the data on Federal Reserve Form FR HMDA-LAR or in an

automated format in accordance with the instructions, except that:

(i) A bank shall maintain the reason(s) it denied a loan

application, using the codes provided in part 203 of this title; and

(ii) A bank shall record all information required by this paragraph

and part 203 of this title within 30 calendar days after the end of

each calendar quarter.

(2) A bank that receives 50 or more home loan applications a year,

as measured by the previous calendar year, and that is not required to

collect data under paragraph (a)(1) of this section, shall record and

maintain for each decision center the following information on home

loan activity:

(i) Number of applications received for each of the following:

Purchase; construction-permanent; refinance.

(ii) Number of loans closed for each of the following: Purchase;

construction-permanent; refinance.

(iii) Number of loans denied for each of the following: Purchase;

construction-permanent; refinance.

(iv) Number of loans withdrawn by applicant, for each of the

following: Purchase; construction-permanent; refinance.

(3) The information required to be maintained under paragraph

(a)(2) of this section shall be updated quarterly, within 30 calendar

days after the end of each calendar quarter, in a format consistent

with the bank's recordkeeping procedures.

(4) A bank exempted under paragraph (a)(2) of this section shall be

covered by that requirement beginning the month following any quarter

in which their average monthly volume of home loan applications exceeds

four applications per month. Banks which are subject to this paragraph

may discontinue keeping this information beginning the month following

two consecutive quarters in which their average monthly volume of home

loan applications drops to four or fewer applications per month. A bank

which is otherwise exempted under this paragraph may be required upon

notification received from the Comptroller, to record and maintain such

information where there is cause to believe that the bank is not in

compliance with the fair housing laws based on prior examinations and/

or has substantive consumer complaints, among other factors.

(5) A bank required to maintain information under paragraph (a)(2)

or (a)(4) of this section may choose to comply with the quarterly

recordkeeping requirement by maintaining information in accordance with

paragraph (a)(1) of this section.

(b) * * *

(1) * * *

(xx) Race/national origin of applicant(s) using the categories:

American Indian or Alaskan Native; Asian or Pacific Islander; Black,

not of Hispanic origin; White, not of Hispanic origin; Hispanic; Other.

* * * * *

3. In Sec. 27.4, paragraph (c)(5) is revised to read as follows:

Sec. 27.4 Inquiry/Application Log.

* * * * *

(c) * * *

(5) Race/national origin of the inquirer(s) or applicant(s) using

the categories: American Indian or Alaskan Native; Asian or Pacific

Islander; Black, not of Hispanic origin; White, not of Hispanic origin;

Hispanic; Other. In the case of inquiries, this item shall be noted on

the basis of visual observation or surname(s) only. In the case of

applications, the information shall be obtained pursuant to

Sec. 27.3(b)(2).

* * * * *

4. In Sec. 27.7, paragraph (b), the introductory text for paragraph

(c), and paragraph (d) are revised to read as follows:

Sec. 27.7 Availability, submission and use of data.

* * * * *

(b) Prior to a scheduled bank examination, the Comptroller may

request the information maintained under Sec. 27.3(a). A bank required

to maintain information under Sec. 27.3(a)(2) shall submit the

information to the Comptroller on the form prescribed in appendix I of

this part. A bank which is exempt from maintaining the information

required under Sec. 27.3(a) shall notify the Comptroller of this fact

in writing within 30 calendar days of its receipt of the Comptroller's

request.

(c) If, upon review of the information maintained under

Sec. 27.3(a), the Comptroller determines that statistical analysis

prior to examination is warranted, the bank will be notified.

* * * * *

(d) If there is cause to believe that a bank is in noncompliance

with fair housing laws, the Comptroller may require submission of

additional Home Loan Data Submission Forms. The Comptroller may also

require submission of the information maintained under Sec. 27.3(a) and

Home Loan Data Submission Forms at more frequent intervals than

specified in paragraphs (b) and (c) of this section.

5. A heading is added preceding Appendix I to read as follows:

Appendixes to Part 27

6. Appendix II is revised to read as follows:

Appendix II--Information for Government Monitoring Purposes

The following language is approved by the Comptroller of the

Currency and will satisfy the requirements of 12 CFR part 27. It may be

inserted to complete the ``Information for Government Monitoring

Purposes'' section of the Residential Loan Application Form (FHLMC Form

65/FNMA 1003) or may be used separately. This information may also be

provided orally by the applicant.

The following information is requested by the Federal Government if

this loan is related to a dwelling, in order to monitor the lender's

compliance with equal credit opportunity and fair housing laws. You are

not required to furnish this information, but are encourage to do so.

The law provides that a lender may neither discriminate on the basis of

this information, nor on whether you choose to furnish it. However, if

you choose not to furnish it, under Federal regulations this lender is

required to note race and sex on the basis of visual observation or

surname. If you do not wish to furnish the above information, please

initial below.

Borrower

I do not wish to furnish this information (initial)________.

Race/National Origin

{time} American Indian or Alaskan Native

{time} Asian or Pacific Islander

{time} Black, not of Hispanic origin

{time} Hispanic

{time} White, not of Hispanic origin

{time} Other (specify)________

Sex

{time} Female

{time} Male

Co-borrower

I do not wish to furnish this information (initial)________.

Race/National Origin

{time} American Indian or Alaskan Native

{time} Asian or Pacific Islander

{time} Black, not of Hispanic origin

{time} Hispanic

{time} White, not of Hispanic origin

{time} Other (specify)________

Sex

{time} Female

{time} Male

BILLING CODE 4810-33-P

6. Appendix III is revised to read as follows:

TR20MY94.003

BILLING CODE 4810-33-C

7. Appendix IV is revised to read as follows:

TR20MY94.004

TR20MY94.005

BILLING CODE 4810-33-C

Dated: May 16, 1994.

Eugene A. Ludwig,

Comptroller of the Currency.

[FR Doc. 94-12270 Filed 5-19-94; 8:45 am]

BILLING CODE 4810-33-P

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