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Promontory NewsEugene A. Ludwig Alan S. Blinder Elizabeth McCaul

 

“The consultant of the future may already exist in the guise of Promontory Group, LLC, established by former Comptroller Eugene Ludwig."

--Steve Cocheo, executive editor,  ABA Banking Journal, Dec. 2004 issue

 

Promontory Financial, based in Washington DC, is essentially a firm of bank doctors. Medium-to-large-size banks call it in to help provide expert strategic advice on everything from M&A to Basle capital-adequacy standards. Promontory, because it has seen so many banks in so many different situations, is able to worry on its clients’ behalf about a whole list of things that most bankers might not normally consider.”

-- Felix Salmon,  Euromoney magazine, Sept. 2003

 

Promontory News

Sept. 4 , 2007 | Article – Rob Garver, ”The Dangers of Buying an Unfamiliar Business” – American Banker
In less than 90 days Sterling Financial Corp. in Lancaster, Pa., went from being a well-regarded banking company that delivered strong returns to shareholders to a bargain-basement takeover target. Read more

Jan. 25, 2007 | 20-Year OCC Veteran Jeff Brown to Lead Basel II Group at Promontory
Promontory Financial Group announced today that Jeffrey A. Brown, former Senior Deputy Comptroller for International and Economic Affairs at the U.S. Office of the Comptroller of the Currency (OCC), has joined the firm as Managing Director leading the Economic Capital and Basel II group. Read more

Sept. 11, 2006 | Former Chairman of Australian Prudential Regulation Authority Heads Promontory Financial Group's New Australian Affiliate
Promontory Financial Group founder and CEO Eugene A. Ludwig today announced that Jeffrey Carmichael, former chairman of the Australian Prudential Authority, will head Promontory’s new Australasian affiliate. Read more

June. 26, 2006 | Andrea Corcoran Joins Promontory Financial Group.
Founder and CEO Eugene A. Ludwig announced today that Andrea Corcoran, former Director of CFTC’s Office of International Affairs, has joined the firm. As a Managing Director in the Washington, D.C., office, Ms. Corcoran will work closely with Mr. Ludwig to provide international financial regulatory and developmental consulting services on domestic and cross-border financial instruments and markets. Read more

May. 2, 2006 | Former Chairmen of the SEC and NASD join forces to lead Securities Practice at Promontory Financial.
Eugene A. Ludwig today announced that two of the securities industry’s most influential regulatory and business leaders—Arthur Levitt and Frank Zarb— will co-chair Promontory Financial Group’s securities practice. Read more

Mar. 27 , 2006 | Roseboro and Wren Join Promontory Financial Group
Eugene A. Ludwig announced today that Brian C. Roseboro, former U.S. Treasury Under Secretary for Domestic Finance and Thomas D. Wren, former MBNA America Bank Treasurer have joined Promontory Financial Group. Read more

Feb. 16 , 2006 | NFA announces Board of Directors election results
Douglas E. Harris, managing director of Promontory Financial Group LLC, has been elected to serve as one of the public directors of the National Futures Association (NFA). Read more

Jan. 13 , 2006 | Article – Robert H. Hartheimer, ”Take a Business Approach to Compliance” – American Banker
Banks need to treat compliance with regulation like a separate business line. Read more

Jan. 11 , 2006 | Former Basel Committee Chairman Padoa-Schioppa Joins Promontory Financial Group as Senior Adviser
Promontory Financial Group announced today that Tommaso Padoa-Schioppa , former Chairman of the Basel Committee on Bank Supervision and newly appointed Chairman of the International Accounting Standards Board (IASB) foundation, has joined the firm as Senior Adviser. Read more

Oct. 6, 2005 | Takuya Fujii Named Chairman of Promontory Financial Group Global Services Japan
Promontory Financial Group, LLC today announced the appointment of Takuya Fujii as Chairman of Promontory Financial Group Global Services Japan, LLC, its subsidiary company based in Tokyo. Read more

Apr. 25 , 2005 | Promontory Financial Group Appoints Three New Officers
Promontory Financial Group announced today the appointment of three new officers with expertise in financial accounting controls, forensic accounting and Federal Reserve regulation and enforcement. Thomas P. Loughlin, Michael P. Joseph, and James J. Hilton join Promontory at a time when the banking industry is facing increased regulatory scrutiny as required by the Sarbanes Oxley Act, the Bank Secrecy Act, and the U.S.A. Patriot Act. Read more

Nov. 19, 2004 | Promontory Welcomes Kathleen Hamm, Peter Holmes, and Beth Potter
Three new officers, with expertise in securities, foreign exchange, risk management, compliance and corporate governance issues, join the offices in New York and Washington, DC.  Read more

June 23, 2004 | Michael A. Dawson Joins Promontory
Michael A. Dawson, who recently left the U.S. Treasury Department where he served as Deputy Assistant Secretary for Critical Infrastructure Protection & Compliance Policy, has joined Promontory Financial Group, LLC, as Managing Director.  Read more

May 26, 2004 | Gwinne Berexa Joins Promontory Asset Finance Company, LLC
Promontory Asset Finance Company, LLC (PAFC) announced today that Gwinne Berexa will join the firm as a Managing Director, expanding PAFC's ability to meet the strong client interest in its innovative financing product.  Read more

May 26, 2004 | New Offices in Tokyo and San Francisco; Douglas Harris, Konrad Alt, and James Rice Join Firm
Promontory Financial Group, a premiere financial and regulatory consultancy for financial institutions throughout the world, announced today the appointment of three new officers, and the opening of new offices in San Francisco and Tokyo, serving the western United States and the Asia-Pacific region, respectively.  Read more

Mar. 24, 2004 | Moody's Rates PAFC New Program - Read more

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Eugene A. Ludwig

Article– "Happy New Year? Don’t Look for One in 2008" – American Banker, January 18, 2008 issue.
The beginning of a new year is a time for predictions. This year, more than most, we should look ahead. Clearly, the financial industry is already in stormy seas, and failure to anticipate the gale winds or icebergs would cost dearly. Read more

Article– "Lessons Gleaned from A Year Full of Upheaval" – American Banker, December 21, 2007 issue.
Looking back over 2007, this certainly has been a year of profound turmoil. Rarely have there been such large reported losses and such significant changes in the management of large financial institutions. Read more

Article– "Risk Management and Corporate Governance" – American Banker, November 16, 2007 issue.
As is readily apparent, we are facing serious challenges in the home mortgage sector. Certainly, there has been no equally challenging time since the late 1980s. Read more

Article– "How to Keep Charters But Gain Coherence" – American Banker, October 19, 2007 issue.
The Treasury Department has reopened the perennial hunt for a more structurally coherent U.S. financial services regulatory mechanism — and no wonder. Read more

Article– "People Primed to Put Deposits in Banks" – American Banker, September 21, 2007 issue.
The current financial crisis has the potential to produce a shift in American finance.
An emerging trend is the rise in importance of banks as intermediaries. Read more

Article– "The Credit Correction's Impact on Banks" – American Banker, August 17, 2007 issue.
The credit correction that began with a re-evaluation of the risk-reward parameters for subrime lending is not over. There will be several very challenging weeks and months before it is. Read more

Article– “Internal Auditing: Lots Of Room for Upgrades” – American Banker, July 20, 2007 issue.
In the real world, auditors cannot be expected to catch every error. At the same time they form the crucial "third line of defense" for financial organizations. As banks become larger and more complex, the importance of internal audit becomes greater. Read more

Article– “Building a Top-Tier Compliance System” – American Banker, June 15, 2007 issue.
Banking organizations' compliance responsibilities are dynamic. Starting from a modest set of requirements several years ago, the standards today for a quality compliance department are high and getting higher. Read more

Article– “It's Imperative: Find Value in Data Flood” – American Banker, May 18, 2007 issue.
The modern banking organization is every day more about systematic information retrieval, analysis, and management. Institutions that are thoughtful about the gathering and analysis of information flows gain a competitive advantage in the marketplace that can translate into enhanced profitability in comparison with their peers. Read more

Article– “Long-Term Benefits of Tighter Standards” – American Banker, April 20, 2007 issue.
Today's difficulties in the subprime credit markets are the canary in the coal mine. Weakness -- perhaps not so serious, but material nonetheless -- also will be left in he housing, commercial real estate, and C&I loan markets in the months ahead. Read more

Article– “Ending Obsession with Quarterly Profits” – American Banker, March 16, 2007 issue.
Investors and others should stop the excessive and counterproductive focus on a financial institution's quarterly earnings. In all businesses, excessive focus on quarterly earning motivates behaviors that are counterproductive in terms of long-term interests. Read more

Article– “Enforcement Disconnect Causes Undue Harm” – American Banker, February 23, 2007 issue.
In many ways the financial services regulatory system has served the country well. Our dual banking system has ensured the continuation of more flexibility ad dynamism than exists in many other developed countries. Read more

\› Article– “Can a Structured Portfolio Weather Coming Storm?” – American Banker, January 19, 2007 issue.
The leading edge of this economic down cycle's tsunami is just beginning to hit individual financial institutions. How widespread the effects will be cannot yet be determined, but it is clear they will be devastating for some financial firms. Read more

Article– “Prepare for Tougher Subprime Standards” – American Banker, December 22, 2006 issue.
The coming year will see a shift in the focus of the House Financial Institutions and Senate Banking committees because of the new leadership in Congress. One key area of change will be a heightened concern over predatory lending practices. Read more

Article– “Weak Risk Reports: Top Execs Must Act” – American Banker, November 17, 2006 issue.
Over the past 10 years financial institutions have made enormous strides in risk management. They have advanced traditional disciplines, significantly improving their capacity to identify, measure, and monitor risk. They have also made great progress in creating and implementing new instruments that allow financial institutions to use risk transfer as a key risk management tool. Read more

Article– “The Value of Enterprise Risk Management” – American Banker, October 20, 2006 issue.
Unfortunately, pressure continues unabated from analysts and investors who want financial services companies' senior managers to increase quarterly profits in the face of weaker economic conditions. Read more

Article– “How to Minimize Risk Of Tail-Event Damage” – American Banker, September 29, 2006 issue.
Tail events are the hardest components of a financial institution’s risks to monitor and mitigate, yet they can be the biggest threats to an institution’s well-being. Although the losses from these events are episodic and idiosyncratic, they can be enormous. Read more

Article– “Room to Improve Terror Financing Rules” – Eugene A. Ludwig and Michael Dawson, American Banker, September 22, 2006 issue.
The fight against terrorist financing has been one of the main elements in the federal government's "war on terror," and has been widely applauded. But while financial services executives and government officials deserve a great deal of credit for making this program work, aspects of the effort have been controversial among many constituencies, including some financial services companies and foreign governments. Read more

Article– “Elements of Basel II That Debate Won’t Alter” – American Banker, August 18, 2006 issue.
A healthy debate is evolving over the precise shape that Basel II capital requirements should take in the United
States. This is a serious matter and it is a mark of distinction in our great democratic system that the debate is now
broad and deep, involving banks large and small, the regulatory community, and the Congress. Read more

Article– “Focusing on Quarterly Data an Unhealthy Habit” – American Banker, July 28, 2006 issue.
The quarterly focus by analysts and some investors on financial services companies’ performance — so much in evidence recently — is both wrongheaded and corrosive. Read more

Article– “Risk Transfer, Part II: Hedge Funds’ Role” – American Banker, June 23, 2006 issue.
Hedge funds are major new entrants into the credit markets. Some observers note these funds bring greater efficiency, stability, and depth to our financial markets generally and the credit markets in particular. Read more

Article– “The Coming Storm in Risk Transference” – American Banker, May 19, 2006 issue.
Current macro-economic conditions make it more likely that we are heading into a less benign credit environment over the next 12 to 36 months than we have enjoyed over the past several years. Read more

Article– “Some Easy Ways to Foster A Sales Culture” – American Banker, April 21, 2006 issue.
Bank profits are increasingly being squeezed. Margin pressures will continue for the foreseeable future. Some of this is the result of the flat yield curve, and some of it is the result of intense competition. Read more

Article– “Price Isn’t Key Funding-Quality Measure” – American Banker, March 17, 2006 issue.
Quality of funding can be measured in two ways. First, it can be measured by the stability of the price, duration, and availability. Second, it can be measured by the extent to which it reinforces the customer relationships that are key to the bank franchise. Read more

Article– “A Role for CEO in Ensuring Audit Quality” – American Banker, February 17, 2006 issue.
One of the questions that the regulators ask when a bank has a serious problem is: “What did internal audit find?” In a preponderance of the cases that we have seen in which a financial institution had a serious problem, the internal audit department had not identified the problem in advance. Read more

Article– “Active Management Program for Tail Risk” – American Banker, January 20, 2006 issue.
All financial services businesses are threatened to a greater or lesser extent by the phenomenon known as tail risk — that is, the risk of an unlikely event that can create catastrophic results. A rogue trader and devastating hurricanes are examples of tail risk.
In fact, for several reasons, tail risk is a much greater threat to banks and other financial institutions than many observers of this sector appreciate. Read more

Article– “Delinquency Statistics Understate the Risks” – American Banker, December 23, 2005 issue.
There are many reasons for bankers to celebrate what has been over all a solid year for their industry. Even though interest rates have been rising and margins compressing, banks have been quite profitable. And if we get through this quarter we will have gone 18 months without a bank failure in the United States. That has not happened before in the entire time the FDIC has been keeping records, starting in 1934. Read more

Article–"Old Issues for New Banking Agency Chiefs" - American Banker, November 18, 2005 issue.
We are in the midst of a complete changing of the guard at the bank regulatory agencies in Washington, the most sweeping in decades. Just think of it: There will be new heads of the Fed, the OCC, the SEC, the FDIC, and the OTS. Read More

Article– “Helping Hurricane Victims Fiscally Wise” – American Banker, October 21, 2005 issue.
Ecclesiastes reminds us that for everything there is a season. And this is the season for Congress and the Bush administration to show compassion toward the victims of Katrina and Rita, including, importantly, the affected banks. Read more

Article– “Don’t Let Security Fears Stifle Innovation” – American Banker, September 23, 2005 issue.
The acquisition, creative analysis, and transfer of information have been at the heart of banking since the Medicis.  However, moving from paper and pen to computer driven methods of dealing with information has created a qualitative revolution. Gathering and analyzing data millions. Read more

Article– “It’s a Dangerous Time For Credit Shenanigans” – American Banker, August 26, 2005 issue.
Storm clouds are gathering. Twenty-four to 36 months from now we will probably be in the unpleasant part of the credit cycle. Just look at the signs. On the corporate side, the Fed’s Beige Book shows commercial and industrial lending taking off just as credit standards are withering. Read more

Article– “Sarbox’ Confers Valuable Benefits In Merger Game” – American Banker, July 15, 2005 issue.
While I was in China on business recently, a high-ranking official of the Chinese government surprised me by wanting to talk about how Chinese banks might best comply with the Sarbanes Oxley Act — or, as he called it, “Sarbox.” Read more

Article– “Heavier Burden On Banks Imperils All Financial Firms” – American Banker, June 17, 2005 issue.
We make a major mistake by not leveling the regulatory playing field. Burdening financial companies that own banks, however small, more heavily than those that do not makes the entire financial services sector less stable. Read more

Article– “Ignore Spirit of Rules at Your Own Risk” – American Banker, May 20, 2005 issue.
Perhaps it is the baseball season that compels me to invent a Yogi Berraism — “The law just ain’t legal anymore” — to describe an important trend that is greatly affecting most of corporate America. Read more

Article– “How to Tell If You've Diversified Too Much” – American Banker, April 22, 2005 issue.
Today's banking world is paradoxical in many ways. Financial institutions have better financial performance, including safety and soundness fundamentals, and deliver increasingly diverse and useful services to consumers.Read more

Article– “What to Do When Controls Break Down” – American Banker, March 18, 2005 issue.
Every several years every financial institution is almost certain to face a serious breakdown of internal controls that leads to some level of crisis. A crisis-management program can be of considerable assistance in mitigating the severity of those crises. Read more

Article– “How to Prepare for Your Inevitable Crisis” – American Banker, February 18, 2005 issue.
Though the timing is not as certain as the 17-year cicada, finance is unmistakably cyclical. It is, for example, nearly certain that every financial institution will suffer breakdowns of internal controls from time to time, and serious ones at least once a decade or so. Read more

Article– “A Time to Shore Up Funding, Keep Credit Standards Tight” – American Banker, January 21, 2005 issue.
The idea that now is the time to focus on liquidity and credit quality may strike some as a bit surprising. After all, bank deposits continue to grow steadily. Over the first three quarters of last year alone, total deposits grew by 7%. Read more

Article– “Five Key Factors That Will Affect The Bank Business Next Year” – American Banker, December 17, 2004 issue.
This has been a challenging year for many financial institutions — margins down, regulation up, and commercial and industrial loan demand weak. To their credit, they survived it; most even did well. Next year the financial climate is likely to be somewhat harsher and the economy and regulators less forgiving. Read more

Article– “Don’t Let Your Temper Make A Bad Exam Report Worse” – American Banker, November 12, 2004 issue.
It happens surprisingly often these days: The chief executive officer is working to meet his many obligations and set priorities. He has solid earnings with steady growth. Yet in comes the regulator for an extremely unsettling meeting concerning a negative report of examination, or worse still, the threat of an enforcement action. Read more

Article– “Spotting Compliance Flaws Before They Become Trouble” – American Banker, October 15, 2004 issue.
Today a troubled bank might not have serious credit quality problems, but its vulnerability might lie in compliance weaknesses. Read more



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Alan S. Blinder

Bank of Spain Conference- “Monetary Policy Today: Sixteen Questions and about Twelve Answers” -- June 8-9, 2006.
My assignment is to survey the main questions swirling around monetary policy today. I emphasize three words in this sentence, each for a different reason. “Main” is because one person’s side issue is another’s main issue. So I had to be both selective and judgmental in compiling my list, else this paper would have been even longer than it is. Read more

Transcript– “Nightly Business Report” - Remember Horton the elephant --June 5, 2006.
About a month ago, an off-the-cuff remark by Chairman Ben Bernanke set off a major flap over Federal Reserve communications. Bernanke told a reporter that his April 27th Congressional testimony had been misunderstood. But he later apologized for his "lapse of judgment" in saying so. Read more

Transcript– “Nightly Business Report” - Economic co-dependency --May 1, 2006.
Chinese President Hu Jintao's recent visit to the White House reminds us of the unhealthy co-dependence that has developed between our two countries. In a nutshell, they need us to buy their goods, and we need them to buy our bonds. Read more

Transcript– “Nightly Business Report” - The Nightly Business Report --February 27, 2006.
Oil traders in New York push the price of crude down almost $2 a barrel today. The move comes on an evening of concern about events halfway around the globe and it helps spur stocks on Wall Street. Read more

Transcript– “Nightly Business Report” - The Nightly Business Report --January 30, 2006.
The trial of Enron`s two top executives finally got underway in Houston today more than four years after the spectacular collapse of the energy trading companyThe trial of Enron`s two top executives finally got underway in Houston today more than four years after the spectacular collapse of the energy trading company. Read more

Transcript– “Nightly Business Report” - Congress, We Have a Problem --December 19, 2005.
If you've paid only sporadic attention to the haggling over the federal budget in recent weeks, you may have come away with the impression that Congress was engaged in a serious struggle over reducing the deficit. Well, not exactly. Read more

Transcript– “Nightly Business Report” - The End of An Era --November 28, 2005.
About a month ago, Ben Bernanke, a former Princeton professor, was nominated to be Chairman of the Federal Reserve Board. Two weeks ago, Bernanke had his Senate confirmation hearing and vote. Neither event was treated as a Big Story, either by the media or by the financial markets. Read more

Transcript– “Nightly Business Report” - The Cheney Doctrine --October 10, 2005.
Sometimes a lesson can be learned too well. It took economists decades to persuade politicians and the public that the federal budget should not necessarily be balanced every year. Read more

Jackson Hole symposium– “Understanding the Greenspan Standard” --August 26, 2005.
Alan Greenspan was sworn in as Chairman of the Board of Governors of the Federal Reserve System almost exactly 18 years ago. At the time, the Reagan administration was being rocked by the Iran-contra scandal. The Berlin Wall was standing tall while, in the Soviet Union, Mikhail Gorbachev had just presented proposals for perestroika. Read more

Transcript– “Nightly Business Report” - Highway robbery --August 2005 issue.
President Bush has many problems. But one of them is not writer’s cramp. Despite ample provocation from Congress, he has yet to wield his veto pen against any increase in spending—no matter how outrageous. Read more

Transcript– “Nightly Business Report” - Good news on the budget? --July 2005 issue.
Amidst all the Karl Rove hullabaloo, you may have missed it. But the White House issued some good news on the budget earlier this month. It now believes the deficit for the current fiscal year will be only $333 billion. Read more

Transcript– “Nightly Business Report” - Is there a housing bubble? --June 2005 issue.
The financial question of the month seems to be: Are we now in a dangerous house price bubble? I have a straightforward answer: no. But I better explain what I mean. Or rather, what I don’t mean. Read more

Transcript– “Nightly Business Report” - Don Quixote Economics --May 2005 issue.
Since I hold no official position, I’m allowed to tilt at windmills now and then. So here goes: Over the next few months, Congress will take up the President’s budget proposals, a major component of which is to make all the tax cuts permanent. So it’s not too late for members of Congress to have a sudden attack of fiscal sanity and reject the idea. Read more

Transcript– “Nightly Business Report” - So why? --March 2005 issue.
When the debate over Social Security reform began, advocates of privatization offered three main arguments in favor of their position. The first was the virtues of choice. Let people control their own money, and they will invest it more wisely than the government. Read more

Presentation Slides – “ASFConference ” - If You Were Alan Greenspan, What Would You Do?--January 25,2005. Read more

Presentation Slides – “Banque de France” - Productivity and Monetary Policy: Lessons from U.S. Experience?--January 19,2005. Read more

Transcript– “Nightly Business Report” - To choose or not to choose --January 2005 issue.
Recent press reports suggest that President Bush may enunciate only broad principles for Social Security privatization, rather than a detailed plan. One of those principles will presumably be individual choice. Read more



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Alfred H. Moses



Haaretz newpaper – One Middle East Policy, For All – April 1, 2005.
There is again a glimmer of hope for a political settlement in the Middle East that will allow two fully democratic states, Israel and Palestine, to live in peace and security. Read more

International Herald Tribune - It Is Time To Call A Halt -- January 08, 2002.
On December 5 a conference of High Contracting Parties to the Fourth Geneva Convention will perfunctorily adopt, without debate, a declaration singling out Israel for condemnation for its security measures in the occupied territories. Read more


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Elizabeth McCaul

Keynote Address at the American Securitization Forum - What's Ahead for the US Residential Mortgage Market? -- January 29,   2007.
Good morning! We gather here today at this terrific conference in good times….markets are generally favorable, the economy looks generally good. And you are involved in a segment of the market that can take significant credit for the good times we are experiencing! Read more

Conference on Investment Management Regulation - Restoring Trust and Confidence of America's Investors in Mutual Funds --   October 28, 2004.
How do you restore investors' confidence in mutual funds? There is no one answer, but running a clean shop with an A-plus reputation certainly provides a start. Read more

Elizabeth McCaul, until recently the Superintendent of Banking for New York State, has moved to Promontory Financial Group as a partner, the firm announced today. Read more


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Kathleen M. Hamm


Loan-Loss Provisions: How to Serve 2 Masters – April 5, 2007.
With the bar raised on corporate governance expectations, bankers must work harder than ever to ensure that new board members from nonfinancial industries understand some of the unique obligations imposed on them as bank directors. Read more


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Jeffrey Brown and C. Erik Larson


The Issue of Retail Credit Risk Seasoning and Its Impact Upon Basel II PD Estimation – June 26, 2007.
When quantifying Basel II PD parameters for segments of retail portfolios, the U.S. supervisors expect banks to take into account the "seasoning" of the accounts in the segment. Read more


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Alfred Moses