Carla Brooks isn't a banker, but the managing director and deputy portfolio manager at Commerce Street Capital LLC, has been on the front lines of the banking crisis.

She has been directly involved in turning around eight troubled institutions held in two of Commerce Street's private-equity funds, helping them open a dialogue with regulators, work out loans or raise capital.

Last fall, she was hired by the Ford Group to complete the application and related financial projections needed for what was then a new type of national bank "shelf-charter" that would allow the Texas private-equity group to bid in FDIC auctions of troubled banks.

Her boutique investment bank last year launched another private-equity fund to take substantial control positions in financial institutions, where regulation permits, using special purpose vehicles. (The fund isn't pursuing a shelf charter, but Brooks would like to use it to pair up with a financial institution that does have the ability to acquire a failed bank.)

Brooks says she drew on her more than three decades of experience regulating, advising and working in banks to help her sell regulators on the idea of the shelf charter. "Lots of these people I've worked with for so long, it's just a [matter of making a] phone call."

A number of private-equity firms have since obtained the special charter, though, as of early September, none had succeeded in using the charter to strike a deal. Still, Brooks says it is only a matter of time before more private-equity firms start winning bids for troubled or failed banks because the healthy banks that are now doing much of the acquiring can only take on so many.

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