The Comptroller of the Currency wants your complaints.

To prove he's serious, Eugene A. Ludwig has hired an ombudsman.

"I think people will complain to the ombudsman on all kinds of things that the agency has done wrong," Mr. Ludwig said. "This isn't just another Washington bureaucratic exercise."

The Comptroller has received just 90 appeals of its examinations since 1991. Mr. Ludwig figures there are more bankers who have grievances but are afraid of retribution from examiners. He intends to make it as easy as possible for them to air their objections.

19 Years as Examiner

Enter Sam Golden, who starts work Wednesday as the OCC's first ombudsman. He has spent 19 of his 41 years examining national banks from Houston.

Here's how the new system. will work:

To appeal an examiner's decision to the ombudsman, national banks first should describe the difference of opinion in writing.

Mr. Golden then will contact the examiner involved. He will have to submit his side of the story in writing.

The ombudsman will issue a written response within 30 days.

Can-Do Attitude

Mr. Golden is a man of linebacker proportions and a winning, can-do attitude. He is determined to make the ombudsman's office a success.

"I want them [bankers] to know that they can call on any issue without any fear whatsoever of any retaliation or retribution coming from any source within the agency," Mr. Golden said. He quickly added this assurance for examiners: "They won't be disadvantaged in any way by anything that we do."

He is positive bankers will use the OCC's new appeals process. Industry representatives are less confident.

"Bankers are not going to appeal the decision of an examiner if they think the examiner can get even," said James McLaughlin, director of agency relations at the American Bankers Association. "It is going to take a lot more than naming an ombudsman to make most bankers comfortable."

Mr. McLaughlin admitted that he does not know how to fix this fear of retaliation.

Mr. Golden conceded. "The fear of retribution is very real."

"I think it is an extraordinarily legitimate issue," he said. "I don't think it is one of these snowballs that every banker has gotten onto just because someone else has said it."

Mr. Ludwig said he plans to deal with get-even examiners by doling out tough punishments.

"We will deal harshly with retribution. That is unacceptable. Absolutely unacceptable."

Appeals Are Expected

In fact, Mr. Ludwig said he wants to see appeals and promises not to downgrade examiners who lose them.

"I've said to examiners if we don't see some appeals, I'm going to wonder what's wrong," Mr. Ludwig said.

Mr. Ludwig said he expects bankers will continue to use the existing appeals process for technical differences with examiners. The ombudsman is likely to be used for "the more serious global matters."

Mr. Golden said he plans to spend his first six to eight months promoting the new process before banker groups across the country.

Staying Out of Washington

Mr. Golden will remain in Houston. "We believe the perception of the industry would be far better if the location was not here within the Washington office," he said.

To start, the office will consist only of Mr. Golden and an assistant he has yet to select.

To reach the ombudsman, call (713) 650-0475.

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