INTERAGENCY AGREEMENT

Procedures for Cooperation Between the Federal Financial Institution
Regulatory Agencies and the Department of Labor in the Enforcement of the
Employee Retirement Income Security Act of 1974.


     The Board of Governors of the Federal Reserve System, Federal Deposit
Insurance Corporation, Federal Home Loan Bank Board, National Credit Union
Administration, and the Office the Comptroller of the Currency ("the
federal financial institution regulatory agencies") as part of their
supervision of the institutions regulated by them, conduct examinations
and perform other functions which occasionally disclose violations of the
Employee Retirement Income Security Act of 1974 (ERISA). The Department of
Labor (DOL) is charged with the administration, interpretation and
enforcement of standards of conduct and responsibility of fiduciaries of
employee benefit plans under ERISA.

     Section 3004(b) of ERISA provides that the Secretary of Labor may
utilize the facilities or services of any department, agency, or
establishment; and each department, agency or establishment of the United
States is authorized and directed to cooperate with the Secretary of Labor
and, to the extent permitted by law, to provide such information and
facilities as the Secretary may request for his assistance in the
performance of his functions under ERISA. This agreement is executed
pursuant to that authority.

1.     To the maximum extent consistent with law and dependent upon the
availability of resources, the federal financial institution regulatory
agencies shall provide written notification to the DOL of possible
violations of ERISA of a significant nature, which are discovered in the
course of their supervision of the fiduciary activities of institutions
subject to their respective jurisdiction. The responsibility of The
National Credit Union Administration shall be limited to possible
violations disclosed in the examination of federal credit unions.

2.   A possible violation shall be considered significant when, in the
view of the appropriate federal financial institution regulatory agency,
it falls within the following circumstances:

a. Where the financial institution does not serve as a plan administrator
or plan sponsor, as those terms are defined in ERISA Section 3(16),
possible violations of:

(1)   Title I, Part 4, Section 404, relating to fiduciary duties
      (including transactions directed by named fiduciaries or 
      qualified investment managers), except where the
      transaction amounts, individually or in combination with
      other questionable transactions, constitute less than
      $100,000;

(2)   Title I, Part 4, Sections 406 and 407(a), relating to
       prohibited transactions, except where the threat of loss to
       the plan participants is de minimus;

(3)   Title I, Part 4, Section 411, relating to prohibition
       against certain persons holding certain positions;

(4)   Title I, Part 4, Section 412, relating to the bonding
        requirements as applicable to the financial institution
        itself.

b. Where the financial institution, in respect to a plan, also serves as
plan administrator or plan sponsor, the agencies shall provide written
notification of possible violation of the ERISA section enumerated in a.
above and, in addition, shall provide written notification of possible
violations of Title I, Part I of ERISA relating to reporting and
disclosure.

3. The written notification to the DOL shall include the following:

a. The name of the financial institution.

b. The name of the plan.

c. A brief description of the nature of the possible violation and any
corrective action requested by the federal financial institution
regulatory agency and/or initiated by the federal financial institution
regulatory agency.

4. The DOL agrees that any information received from the federal financial
institution regulatory agencies pursuant to this agreement shall to the
extent permissible by law be held in strict confidence and may be used for
investigative purposes only; and that no other use of such information
shall be made without the express written authorization of the agency that
supplied such information.

5.  The written notification shall be sent to the Assistant Administrator
for Enforcement, Pension Welfare Benefit Programs, U.S.  Department of
Labor, Washington, D.C. 20216

For Federal Financial Institution Regulatory Agencies:


Date:  December 9, 1980            Theodore E. Allison, Secretary
                                   Board of Governors of the
                                   Federal Reserve System

Date:  December 11, 1980           Hoyle L. Robinson
                                   Executive Secretary
                                   Federal Deposit Insurance Corporation

Date:  December 10, 1980           L. David Taylor, Director
                                   Office of Examinations and Supervision
                                   Federal Home Loan Bank Board

Date:  December 10, 1980           Rosemary Brady
                                   Secretary of the Board
                                   National Credit Union Administration

Date:  December 12, 1980           Paul M. Homan
                                   Senior Deputy Comptroller for Bank
                                   Supervision
                                   Office of the Comptroller
                                   of the Currency

For the U.S. Department of Labor:

Date:  December 29, 1980           Ian D. Lanoff
                                   Administrator of Pension and Welfare
                                   Benefit Programs