On January 11, the OCC issued an interpretive letter in which it took the position that Section 27(a) of the National Bank Act permits the OCC to charter a national bank that limits its operations to those of a trust company and activities related thereto. According to the interpretive letter, activities of a trust company include activities permissible for a state trust bank or trust company under state law in the state where the national bank is located, such as acting as a custodian, even if those state authorized activities are not necessarily considered fiduciary in nature under federal law. The letter goes on to explain that a national trust bank may be permitted to engage in any and all activities permitted under state law for a state trust company and may also engage in activities beyond those authorized under state law for a state trust company provided such activities are permitted for a national bank under other provisions of the National Bank Act, raising the possibility that a limited purpose national bank could potentially be organized to perform trust company functions and other permissible functions such as lending and payments
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