To the Editor:

Unfortunately, the lead paragraph of your story (Feb. 18, page 2) on the OTS' processing of trust-only charter applications misstates both the status of these applications and the reasons for that status.

OTS has not suspended the processing of these applications, just the time period for completing our review.

There is a big difference, because actual processing continues both as we resolve unique issues with individual applications and as we review significant issues that are common to several trust applications.

One common question, for example, is the appropriate degree of independence of a thrift exercising discretionary fiduciary power from an affiliate entity offering proprietary investment products.

More importantly, OTS does have the ability and is already supervising institutions that provide trust services. It is in fact our ongoing supervision of such institutions that has convinced us that there are difficult issues to address and resolve as we conscientiously process these applications in the public interest.

Richard M. Riccobono

Deputy director Office of Thrift Supervision Washington

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