To the Editor:

I am shocked that the Administration would preempt Julie William's succession to the position of Acting Comptroller of the Currency - a role she has filled with great skill on two past occasions. The personal nature of this action is underscored by the fact that as the First Deputy Comptroller Julie would be expected to assume the role of Acting Comptroller under the OCC's established rules of succession.

There is no lawyer in the country more knowledgeable than Julie on matters of financial regulation and policy, and no one who has added greater strength to the OCC and to the national banking system. She has had a distinguished career as a public servant, and the unfortunate message that this Administration has sent is that long and valuable service will take second place to temporal politics. One can only hope that the OCC will continue to realize the benefit of Julie's unmatched expertise as Chief Counsel.

Some have suggested that Julie's lead role in defending national bank preemption was a cause of this decision. It would be incredible to me that someone who has taken an oath to support and defend the Constitution of the United States would be publicly sanctioned for doing just that. Preemption is, of course, a constitutional doctrine, and despite the misconception of some that it was invented during Julie's tenure, the Supremacy Clause is not a law that public officials can waive or ignore.

Those responsible for this very unfortunate decision should be ashamed of themselves.

John D. Hawke, Jr.
28th Comptroller of the Currency

Editor's Note: John D. Hawke Jr. is a partner at Arnold and Porter LLP. He was comptroller from 1998 to 2004

Subscribe Now

Access to authoritative analysis and perspective and our data-driven report series.

14-Day Free Trial

No credit card required. Complete access to articles, breaking news and industry data.