David W. Smith

ASSISTANT VICE PRESIDENT

September 24, 1998

CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Mr. John M. Stewart
President
Harris Trust/Bank of Montreal
501 South Flagler Drive
West Palm Beach, Florida 33401

Dear Mr. Stewart:

This is in reference to the application by Harris Trust/Bank of Montreal, West Palm Beach, Florida (Bank), to establish a branch office located at 2940 Cardinal Drive, Vero Beach, Florida, pursuant to Section 9 of the Federal Reserve Act.

The Board of Governors of the Federal Reserve System has amended the procedures for establishing a branch, which, based upon certain criteria, allow a state member bank to open a branch on the fifth business day after the expiration of a one-time, 30-day newspaper comment period unless notified to the contrary by the Reserve Bank. Criteria for these procedures include a satisfactory financial condition, an adequate capital level in relation to assets, a satisfactory record of performance under the Community Reinvestment Act, satisfactory compliance with laws and regulations, compliance with any supervisory directives, and require that any increase in the bank's investment in premises in connection with the proposal be in compliance with section 24A of the Federal Reserve Act.

Because Bank meets the requirements for these amended procedures, the transaction may be consummated five business days after expiration of the comment period, or October 22, 1998, unless notified to the contrary by the Reserve Bank. Approval is subject to Bank's obtaining approval from the appropriate state banking authority and to the proposal's consummation within one year from October 22, 1998. Please advise this office in writing one week prior to the opening of the branch.

Until further notice, future branch applications by Bank may consist of a letter describing the proposal, a copy of the newspaper notice, and a publisher's affidavit. Branch applications should be submitted within seven calendar days of publication. If the publisher's affidavit is not available within seven calendar days of publication, Bank should submit a newspaper page containing the notice and evidence of the date of publication. The publisher's affidavit should be forwarded as soon as it becomes available.

Should you have any questions regarding this matter, please contact Robert D. Scheffel of our staff at (404) 589-7220.

Very truly yours,

David W. Smith

cc:	Board of Governors Florida State Banking Authority Bruce H. Roberson, Esquire

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