FEDERAL DEPOSIT INSURANCE CORPORATION

RE: Howard Savings Bank Glenview, Illinois

Application Pursuant to Section 24(a) of the Federal Deposit Insurance Act to Indirectly Continue Activity That May Not be Permissible for a National Bank

STATEMENT

Pursuant to the provisions of section 24 of the Federal Deposit Insurance Act, an application has been filed with the Federal Deposit Insurance Corporation by Howard Savings Bank, Glenview, Illinois ("Howard"). The application requests the Corporation's consent to continue engaging, through a wholly-owned subsidiary, in real estate development activities. Howard has been operating under an approved divestiture plan involving several parcels of real estate, one of which has been sold and another which has been partially divested. Real estate activities will be conducted through a wholly-owned subsidiary and will require only nominal financial and managerial resources.

The applicant has committed to preserving its present conservative operating safeguards and establishing investment limits to prevent credit concentrations. The applicant exceeds all applicable minimum capital standards and continuation of this activity as proposed does not appear to pose significant risk to the Savings Association Insurance Fund.

Accordingly, the Division of Supervision has concluded that the application should be approved.