Gene Ludwig | |
---|---|
27th Comptroller of the Currency | |
In office April 5, 1993 - April 3, 1998 | |
President | Bill Clinton |
Preceded by | Robert L. Clarke |
Succeeded by | John D. Hawke Jr. |
Personal details | |
Born | New York City,New York,U.S. | April 11,1946
Spouse | Carol Ludwig |
Children | 3 |
Education | Haverford College (BA) New College,Oxford (MA) Yale University (JD) |
Eugene A. "Gene" Ludwig (born April 11,1946) is an American business leader and expert on banking regulation,risk management,and fiscal policy. He is the founder and former CEO and chairman of Promontory Financial Group,an IBM Company,a global risk management and regulatory compliance consulting firm focusing primarily on the financial services industry. Ludwig is currently co-managing partner of Canapi Ventures,a venture capital firm focused on investments in early to growth-stage fintech companies,CEO of Ludwig Advisors,which advises financial firms on critical matters,and chairman of the Ludwig Institute for Shared Economic Prosperity (LISEP),a non-profit organization dedicated to improving the economic well-being of middle- and lower-income Americans through research and education. He is also the former vice chairman of Bankers Trust and Deutsche Bank,and from 1993 to 1998 served as President Clinton's Comptroller of the Currency.
Ludwig was born in Brooklyn,New York, [1] to Jacob S. and Louise Rabiner Ludwig. [2] He was raised in York,Pennsylvania,attending public schools. [3] His father was a country doctor who took his son with him to get his first office loan. [4] His mother was a former Broadway chorus girl. [5] His younger brother Ken Ludwig is a playwright. "Dear Jack,Dear Louise," a play by Ludwig's brother based on their parents' courtship during World War II,opened at Arena Stage in December 2019. [6]
Ludwig received his undergraduate degree magna cum laude from Haverford College in 1968 and was initiated into Phi Beta Kappa. He received a scholarship to Oxford University,where he studied philosophy,politics and economics at New College and earned a Masters of Arts as a Keasbey Fellow. He holds a J.D. degree from Yale Law School,where he was an editor of the Yale Law Journal and president of Yale Legislative Services. [7] He is a Wykeham Fellow at New College,Oxford. [8] Ludwig lives in Washington,D.C. He is married to Dr. Carol Ludwig,and they have three children.
Ludwig joined the law firm of Covington and Burling in 1973 and became a partner in 1981. He specialized in intellectual property law,banking,and international trade. In 1987,' The New York Times' described him as a leader in the fight against gray-market goods,which are goods manufactured overseas and imported without the consent of the trademark holder. Ludwig called the practice "consumer deception." [9]
In 1993,President Bill Clinton selected Ludwig to become the 27th Comptroller of the Currency,responsible for chartering,regulating,and supervising national banks and the federal branches and agencies of foreign banks. As Comptroller,Ludwig led the agency through a period of substantial change,both within the financial marketplace as well as in the supervisory and examination practices of the agency. Ludwig took office at time of economic upheaval,following a recession that yielded a spike in bank failures and amid a credit crunch that had persisted for several years. [10] He took the lead in regulators’1993 initiatives to alleviate a lingering credit crunch by encouraging banks to increase lending, [11] and later described the results as “dramatic.”He said:“The credit crunch abated,the economy began to grow again and the banking industry returned to good health.” [12]
Ludwig improved safety and soundness supervision through adoption of "supervision by risk", [13] an approach that has been adopted by many other supervisory agencies. [14]
Ludwig also led President Clinton's initiatives to reform the Community Reinvestment Act and more vigorously enforce the fair lending laws. [15] In December 1993,Ludwig was singled out by then-Secretary of the Treasury Robert Rubin,who praised “his efforts to make CRA reform a reality." [16]
During five years in office,Ludwig oversaw 4,000 fair lending examinations of national banks and made 25 referrals of fair lending violations to the Department of Justice and the Department of Housing and Urban Development. Previously,there had been only one such referral to a federal agency charged with fair lending enforcement. [17]
As Comptroller,Ludwig served as a member of the Basel Committee on Bank Supervision,a director of the Federal Deposit Insurance Corporation,and a director of the Neighborhood Reinvestment Corporation. [18]
Reflecting on his service as Comptroller in April 2010,Ludwig testified before the U.S. House Subcommittee on Financial Institutions and Consumer Credit that "credit made available to low- and moderate-income Americans through CRA programs during ... the 1990s was not only transforming for low- and moderate-income communities,but it was almost without exception profitable and safe." [19]
Ludwig served as vice chairman of Bankers Trust/Deutsche Bank from April 1998 [20] to December 31,1999. [21] During his time there,he participated in the rescue negotiations for Long-Term Capital Management,a bond-trading hedge fund that was recapitalized under the Federal Reserve’s guidance by 16 leading financial institutions to prevent its collapse. [22]
In 2001,Ludwig founded Promontory Financial Group,becoming its CEO and chairman. The firm gained attention when,following a $750 million trading scandal at Allied Irish Banks,Promontory produced what became known as "The Ludwig Report," [23] recommending improved compliance and management measures which helped the bank regain its footing. [24] In 2007,after Ludwig advised Countrywide Financial,Portfolio.com wrote that "[Countrywide CEO] Angelo Mozilo is a tough character,and Ludwig is one of the few people with enough clout to persuade him that the game really was up." [25] Business Week reported that Promontory has also advised PNC Financial Services Group,Riggs National Bank,and Citigroup,and helped clean up abuses at AIG. [26] In 2008,Morgan Stanley announced that it had become a client of Ludwig's. [27]
Ludwig is also co-founder and managing partner of Canapi Ventures,a venture capital firm, [28] [29] and founder and CEO of Ludwig Advisors,which advises financial firms on critical matters. Promontory Interfinancial Network,a separate company that Ludwig started in 2003 with former Federal Reserve Vice Chairman Alan Blinder,was sold in 2019 to Blackstone Group. [30] [31]
Since founding Promontory Financial Group,Ludwig has been invited to testify before Congress as an expert witness several times:
In October 2008 testimony to the Senate Banking Committee,Ludwig summarized the origins of the Financial Crisis of 2007-08:“The fundamental story of the current turmoil is relatively easy to tell. It began early in this decade with a weakening of underwriting standards for subprime mortgages in the U.S. Subprime,alt-A and other mortgage products [which] were sold to people who could not afford them and in some cases in violation of legal standards.” [32]
In February 2009,Reuters reported that Ludwig was an advisor to U.S. Senate Banking Committee Chairman Christopher Dodd and U.S. House Speaker Nancy Pelosi,as well as Republican Senator Richard Shelby,among others. [33]
In September 2009,Ludwig testified before the Senate Banking Committee and said,‘‘we must dramatically streamline the current alphabet soup of regulators,’’citing the burden on financial institutions of duplicative supervision,gaps between regulatory responsibilities,and regulatory arbitrage. [34]
In September 2016,IBM announced plans to acquire Promontory,citing its status as “the firm financial institutions turned to for guidance coming out of the 2008 financial crisis.”The transaction was completed in November 2016,and the firm—renamed Promontory Financial Group,an IBM Company—became a wholly owned subsidiary of IBM with Ludwig remaining at the helm until 2021. [35]
IBM,describing Promontory’s expertise in regulation,risk,and compliance as “unsurpassed,”said Promontory’s team of 600 professionals would train IBM’s Watson cognitive computing system to understand a massive volume of regulations and compliance requirements. By harnessing this information,Watson—which combines artificial intelligence with analytical software to support complex decision-making—could accelerate financial institutions’ability to understand regulatory changes and obligations and address compliance requirements,IBM said. [36]
Cognitive computing “has the potential to vastly improve existing approaches to risk management,potentially covering everything from stress testing and capital planning to credit portfolio analysis,risk modeling,and regulatory change management,”Ludwig wrote in Investor’s Business Daily in December 2016. [37]
Ludwig stressed that artificial intelligence would complement,rather than replace,human compliance efforts. [38]
Ludwig is the editor of The Vanishing American Dream, a book that provides comments from experts across the political spectrum on the economic challenges facing lower- and middle-income Americans. [39] [40] The book examines how traditional economic measures like the unemployment rate and GDP are masking a crisis for millions of lower- and middle-income families,who struggle to afford health care,housing,and education and occupy jobs that cannot help them reverse the downward slide. The book,to be published September 22,2020,was the outcome of a 2019 Yale Law School symposium organized by Ludwig. It includes commentary from 23 experts,including economists Lawrence Summers,Glenn Hubbard,and Robert Shiller;former Deputy Treasury Secretary and Federal Reserve Governor Sarah Bloom Raskin;public policy expert and political adviser Oren Cass;and Brooking Institution Senior Fellow Belle Sawhill. Kirkus Reviews called the book a “lively and engrossing work”in which “Ludwig presents a model of public discourse—informed,multidisciplinary,and shorn of myopic ideological commitments.” [41]
Ludwig has written numerous articles on banking,finance,and economic policy for scholarly journals and publications and has been a guest lecturer at Yale and Harvard law schools and Georgetown University's International Law Institute. [42] A theme in Ludwig's speeches and writings has been his conviction that the economic challenges confronting lower- and middle-income Americans are growing urgent. He has noted that real-wage stagnation,combined with dramatic surges in the costs of basics such as education,housing,health care and food,have created a situation in which middle-income households by 2014 were spending 78% of their budgets on basic needs. [43] He has voiced skepticism about strong economic indicators such as gross domestic product and jobs numbers,arguing in a CNBC op-ed in July 2018 that common measures of economic health mask significant and growing disparities between the wealthiest Americans and those in lower- and middle-income brackets. [44] He has also raised concern about what he has described as poorly conceived limits on policymakers' ability to respond forcefully to a severe economic downturn. [45]
In 2008,Ludwig co-authored an essay in The Wall Street Journal with former Federal Reserve Chairman Paul A. Volcker and former U.S. Treasury Secretary Nicholas F. Brady calling for a resurrection of the Resolution Trust Corporation to help deal with the financial crisis. [46] The op-ed was widely discussed and cited,capturing the interest of,among others,then-Treasury Secretary Hank Paulson as he explored solutions to the rapidly unfolding financial crisis. [47]
Date | Title | Publication | Topic |
---|---|---|---|
August 12,2022 | "The true cost of misleading headline inflation statistics" | American Banker | Several key government-reported headline statistics present a distorted view of reality for most Americans,with the impact extending far beyond Wall Street. And it can have dire consequences —particularly when those numbers drive economic policy. (Co-authored with Phillip Cornell.) [48] |
August 3,2022 | "'Too Big to Fail' Again?" | Democracy Journal | Why Washington needs to wake up to the crisis that’s looming in the nonbank financial sector. [49] |
July 15,2022 | "CPI Doesn’t Capture the True Cost of Living in Trump Country" | The Wall Street Journal | The economic squeeze on low- and middle-income Americans is no new phenomenon,a truth that voting patterns have been better at revealing than official inflation data. (Co-authored with Diana Dayoub.) [50] |
June 8,2022 | "Inflation has been pummeling the middle class for decades,but the out-of-touch CPI masks this reality" | MarketWatch | The 'True Cost of Living' index shows millions of low- and middle-income families don't earn enough to buy necessities like shelter,food,and child care. [51] |
April 29,2022 | "Minority-owned banks need more help and fewer setbacks from Washington" | The Hill | Each time the economy falters,a disproportionate number of Minority Depository Institutions find themselves in trouble through no fault of their own. (Co-authored with Nicole A. Elam.) [52] |
January 19,2022 | "Why Are Minority-Owned Banks Disappearing? Washington Holds the Smoking Gun" | Politico | Congress needs to create a new safety net for such lenders —not let regulators squeeze them out of business. [53] |
October 7,2021 | "America’s hidden hedge against inflation" | MarketWatch | There is an enormous (but invisible) supply of labor that companies can hire to keep costs down. [54] |
September 25,2021 | "Measured by creation of good jobs,today's recovery stands alone" | The Hill | For all the misery and carnage wrought by pandemic,these figures hint at the prospect of brighter days ahead. [55] |
July 30,2021 | "Three reforms CDFIs need to help build stronger communities" | American Banker | Community development financial institutions could do more lending in low-income neighborhoods if policymakers relaxed accounting rules,increased government support and encouraged more investment from hedge funds and other nonbank lenders. (Co-authored with Don Riegle.) [56] |
April 21,2021 | "Reforms That Can Help Revive the American Dream" | The Atlantic | A new cadre of financial regulators can transform the financial world’s role in the fight against prejudice and inequality. [57] |
April 19,2021 | "When it comes to Biden's jobs bill,bigger is better" | The Hill | If we more carefully scrutinize the real state of the working and middle class,it’s clear this jobs bill is critical to the country’s future and,if anything,should be more expansive. [58] |
March 3,2021 | "Go Big on COVID Stimulus -- We Can't Afford Not To" | Morning Consult | I am strongly of the belief that concern over the size of Biden’s COVID-19 relief bill is misplaced. The country needs this amount of relief –or more. [59] |
January 25,2021 | "Unemployment is Much Worse Than You Think -- Here's Why." | Politico | The problem for many Americans isn’t getting a job,it’s getting enough hours at decent wages. Our topline numbers obscure that reality. [60] |
October 11,2020 | "US regulators should prod lenders to help minority communities." | Financial Times | Existing rules can be updated to address inequalities exacerbated by Covid-19. [61] |
June 1,2020 | "The write-downs are coming. Start preparing now." | American Banker | The crisis being triggered by the coronavirus pandemic is accelerating the financial industry toward an era of dramatically increased debt workouts and defaults. While the Paycheck Protection Program loans should end up on the government’s books,most loan write-offs and write-downs will be the burden of banks and other lenders. [62] |
May 28,2020 | "How the Fed’s Rescue Program Is Worsening Inequality" | Politico | Analyzed how federal intervention programs to deal with the Covid-19 pandemic are exacerbating inequality. They asserted that by intervening in the high-yield or junk bond market,“Washington is backstopping loans that are predominately purchased by wealthy investors.”(Co-authored with Sarah Bloom Raskin.) [63] |
March 6,2020 | "A Tax Cut Democrats and Republicans Could Agree On? The Payroll Levy" | Washington Post | Argued that both parties have a good reason to get behind an effort to free middle- and working-class families from a disproportionate tax burden. Eliminating the payroll tax could help stimulate the economy,and given the coronavirus outbreak,the time is right. [64] |
February 18,2020 | "Lessons for Bankers from Disasters that Didn't Have to Be" | American Banker | Called on companies to own up to mistakes and problems in order to maintain a strong company culture that is focused on regulation,risk and transparency for maintaining a strong company culture. (Co-authored with Susan Krause Bell and Wayne Rushton.) [65] |
January 31,2020 | "CECL Is a Real Threat to the Financial System" | American Banker | Argued that the Financial Accounting Standards Board has been incorrect in how it limits a bank’s allowance for loan and lease losses and called for reform. [66] |
July 11,2019 | "Payroll Tax Has Become a Monster. It Needs to Be Replaced" | Newsweek | Called for replacing the payroll tax with non-labor taxes,arguing that the payroll tax had become "the biggest tax 80 percent of Americans pay." [67] |
June 20,2019 | "The Key to Rightsizing Regulation" | American Banker | Advocated creation of a "National Institute of Regulation" to examine regulatory effectiveness and efficiency. [68] |
June 11,2019 | "U.S. Regulators Ill Prepared for Next Downturn" | Financial Times | Urged Congress to restore supervisory powers that were stripped away after the 2008 financial crisis. [69] |
May 15,2019 | "Rosy Economic Data Belie a Harsh Reality for Many Americans | The Hill | Argued that lower- and middle-income Americans have not shared in economic advances for decades,and urged policymakers to focus on making community college affordable,promoting financial literacy,and creating more flexible ways for people to work their way out of delinquent debts. [70] |
October 31,2018 | "Warning:The Deregulatory Mood Can't Last Forever" | American Banker | Identified five "good government" reforms that the financial services industry should pursue:Elimination of regulatory duplication,requiring fair rights of appeal in the supervisory process,promoting innovation in banking,improving regulatory effectiveness,and modernizing finance for low-income groups. [71] |
July 6,2018 | "Regulators Have Their Eye on AI" | American Banker | Described artificial intelligence as "an increasingly important tool in finance" that has "the potential to create regulatory problems if it isn’t used carefully." [72] |
April 4,2018 | "America's Economic Challenges" | Banking Exchange | Examined decline in economic opportunities for lower- and middle-class Americans and argued that "economic reality in America is a widening chasm between the wealthy and everyone else,and fueling disquiet in those who struggle economically. [73] |
February 9,2018 | "Getting Ahead of Risk Involves Asking the Right Questions" | American Banker | Focused on how to identify specific ways institutions are vulnerable to risk and raised concern about "groupthink that dismisses a systemic event in the foreseeable future." [74] |
December 20,2017 | "Bankers Should Resolve to Be More Paranoid in 2018" | American Banker | Warned the financial services industry of the risk of economic downturn and cited concern that "a major tail event that will shock the financial indusry is likely in the foreseeable future." [75] |
October 1,2016 | "How America Can Get Out of Its Economic Swamp" | Time | Decried bias in the federal budget process against crucial spending,particularly for infrastructure,education and research. Advocated for the creation of a federal capital budget to provide a framework for long-term expenditures,noting that this approach is used in the private sector and by most state governments. [76] |
March 15,2016 | "Unregulated Shadow Banks Are a Ticking Time Bomb" | American Banker | Critiqued the approach of strictly regulating banks while only loosely regulating nonbank financial institutions,or "shadow banks." [77] |
November 17,2012 | "Banks Need Long-Term Rainy Day Funds" | The Wall Street Journal | Called for accounting reform to ensure that banks could build adequate loan loss reserves well before losses are realized. (Co-authored with Paul A. Volcker) [78] |
December 7,2011 | "Why the Fight Over the Payroll Tax Matters" | The New York Times | Advocated a permanent cut in the payroll tax as a first step toward fundamental tax reform. [79] |
June 25,2010 | "Another View:Now It's Up to the Regulators" | The New York Times | Observed that although Congress had passed financial regulatory reform,the real work of filling in the details would now fall to the regulators. "If the New Deal is credited with creating the regulatory agencies,this bill will be remembered for super-charging their authority." [80] |
February 2009 | “The Community Reinvestment Act:Past Successes and Future Opportunities” | “Revisiting the CRA:Perspectives on the Future of the Community Reinvestment Act,”by the Federal Reserve Banks of Boston and San Francisco | Retrospective and analysis of the Community Reinvestment Act. (Co-authored with James Kamihachi and Laura Toh) [81] |
November 19,2008 | "Don't Junk the U.S. Auto Industry | Reuters | Argued that providing government aid to the three major U.S. automakers would be far more effective than allowing them to go bankrupt. [82] |
September 17,2008 | "Resurrect the Resolution Trust Corp. | The Wall Street Journal | Called for recreation of the Resolution Trust Corporation to help deal with the financial crisis. (Co-authored with former Federal Reserve Chairman Paul A. Volcker and former U.S. Treasury Secretary Nicholas F. Brady. [83] |
Date | Speech | Sponsor/Event/Venue |
---|---|---|
June 5,2019 | Keynote address [84] | World Bank,9th Annual International Conference on Policy Challenges for the Financial Sector,Washington,D.C. |
June 4,2019 | Keynote address [85] | Community Development Bankers Association 2019 Peer Forum,Washington,D.C. |
March 11,2019 | Moderator,“Globalization vs. Fragmentation” [86] | Institute of International Bankers Annual Washington Conference,Washington D.C. |
October 31,2013 | “Supervision in a Time of Change” [87] | The George Washington University Center for Law,Economics &Finance. Washington,D.C. |
October 25,2012 | Panel,"Reformed:Has Financial Regulation Saved the System?" [88] | The Economist 2012 Buttonwood Gathering,New York |
May 11,2012 | Keynote address,“Faith,Judgment,and Rigor:The Role of Capital and Supervision in PostCrisis Financial Regulation” [89] | Federal Reserve Bank of Chicago 48th Annual Conference on Bank Structure and Competition |
February 19,2010 | "Extending Credit to Lower Income Americans Safely and Fairly" [90] | Joint Center for Housing Studies of Harvard UniversityInternational Conference on Banking Supervision,Brussels |
September 25,2008 | William Taylor Memorial Lecture,"We Must Have Supervision and Regulation" [91] | International Conference on Banking Supervision,Brussels |
September 23,2008 | Annual Hagedorn Lecture on Corporate Social Responsibility [92] | Adelphi University,Garden City,N.Y. |
Date | Topic/Quote | Venue |
---|---|---|
July 25,2022 | Podcast:“How High Inflation,High Rates Will Impact Banking" | The Slant (Bank Director magazine) interview with Jack Milligan [93] |
August 14,2019 | Podcast:“Artificial Intelligence,Community Banks,and the Compliance Jobs of the Future." | ABA Banking Journal interview with Evan Sparks [94] |
June 13,2019 | Interview:Elements of Downturn in Economy | CNBC "Squawk on the Street" [95] |
January 1,2017 | Regulatory simplification:“Our regulatory system is far too complex,”he said in a January 2017 radio interview. “Too many agencies create a great deal of burden with no particular benefit. It is an artifact of history,not logic,and it needs to be changed.” | Bloomberg Radio interview with Arthur Levitt |
May 29,2013 | Long-term regulatory trends (video) [96] | Interview with Professor Jeffrey Garten,Yale School of Management |
September 2010 | Expert testimony on causes of the financial crisis of 2007-8 [97] | Financial Crisis Inquiry Commission |
Ludwig is president of The Ludwig Family Foundation Inc.,a charitable organization that focuses on improving education,alleviating poverty,and supporting medical research and the arts. [98] In 2019,The Ludwig Family Foundation created The Ludwig Institute for Shared Economic Prosperity,dedicated to improving the economic well-being of lower-income Americans through research and education. [99]
He is a long-time member of the board of directors of the National Academy Foundation,a New York-based nonprofit that helps prepare low- and moderate-income students for college and careers. [100] Ludwig has also endowed several funds and programs,including the Ludwig Fund for the Humanities at New College,Oxford; [101] the Eugene and Carol Ludwig Center for Community &Economic Development at Yale Law School; [102] and the Ludwig Fund for Community Development at Haverford College. [103]
Ludwig has received numerous awards for excellence and leadership,including the BritishAmerican Business Entrepreneurship Award (2010), [104] National Academy Foundation Leadership Award (2011), [105] Simeon E. Baldwin Award,presented by the Yale Law School Center for the Study of Corporate Law (2011), [106] the Foreign Policy Association Medal (2014), [107] and the Jill Chaifetz Award presented by Advocates for Children (2014.) [108]
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