WASHINGTON -- Talk about living your work.
Alan J. Dombrow, the Comptroller of the Currency's expert on the Truth-in-Savings Act, drives a '91 Ford Escort with license plates that read "Reg Z."
You'd expect that kind of zeal to generate animosity from rule-weary bankers -- especially since Regulation Z is one of the most unpopular rules of all. But many bankers find it difficult not to like the 48-year-old regulator. In fact, Mr. Dombrow is a big hit when he speaks to industry groups because he is enthusiastic, energetic, and empathetic when it comes to complaints about overregulation.
"Compliance is absolutely a frustrating area," he admitted in an interview. "It takes a lot of hours."
His advice? "Make fun of it." It will be interesting to see if Mr. Dombrow can finesse his latest assignment as well.
He is leading a new, five-person OCC task force set up to figure out the best way to test national banks for lending bias.
Comptroller Eugene A. Ludwig stunned the banking industry in May when he announced that his agency would send mock customers into banks to judge whether the institutions are treating minorities the same as whites.
A lot of bankers greeted the news as the latest episode in a reign of regulatory terror. By extension, that would make Mr. Dombrow the Robespierre of the new program.
Not a Simple Exercise
The regulator says his' task force is very circumspect because "testing" is a complex undertaking.
"This area is so new for the OCC," Mr. Dombrow said, adding that his group has not come to any conclusions yet.
To illustrate the kinds of questions with which the task force is wrestling, Mr. Dombrow asked whether the testers should be informed that they are testing the bank for discrimination or be kept in the dark.
"What I've been doing is communicating with a lot of sources to find out what is the state of the art in testing out there," he said.
The testing program is scheduled to begin in early 1994, but Mr. Dombrow said his team is not being held to any firm deadlines.
Mr. Dombrow knows testing is controversial, and he is uncomfortable exploring its details. He prefers to explain the multimedia presentation he has just finished on Truth-in-Lending.
It starts with the theme song from the old "Mission Impossible" television show. A picture of a distressed banker flashes on the screen and the sound track segues into a wild scream.
The presentation is anything but boring, but in case bankers do doze, Mr. Dombrow has built in wake-up calls that play Beethoven's Fifth before important information is displayed.
|I'm Not Their Enemy'
"I just want to let them know I'm not their enemy. We're here to learn and enjoy," Mr. Dombrow said.
Mr. Dombrow's job is to help bankers and examiners understand consumer regulations. He develops exam procedures, trains examiners, and translates regulations into plain language.
Twice a year he travels to Norman, Okla., to deliver a three-day course on complying with Truth-in-Lending.
A self-taught computer guru, Mr. Dombrow has written programs that help bankers comply with Truth-in-Lending, Truth-in-Savings, and the Home Mortgage Disclosure Act. Examiners use the same programs to evaluate compliance.
Bankers input information, and the computer tells them what must be disclosed. Examiners put in what the bank disclosed, and the computer tells them whether the banker calculated it correctly.
After Congress amended Truth-in-Lending in 1988, Mr. Dombrow spent 26 weeks a year on the road explaining the changes to bankers and examiners.
He credits his energy to his physical fitness regime. He quit smoking in 1980 through hypnosis, and he's sure the doctor must have put in a plug for step aerobics while he was under. At least that's how Mr. Dombrow explains his passion for step classes, which he attends three to five times a week.
After 20 years with the agency he is not bored. He admits to writing the HMDA program on vacation. "It's so relaxing," he said sincerely.
Lured by Bank Examiners
Mr. Dombrow got his start in banking at Bank of America in San Diego. The bank's examiners asked him if he wanted to come to work for the government. Mr. Dombrow said he had joined the Navy to "see the world" and figured the OCC offered the same opportunity. So he signed on and spent the next five years examining banks in the West.
"I loved it," he said.
His path to OCC's Washington headquarters was as serendipitous. He was here taking a class, and his boss in California called to tell him about the opening. He interviewed that day and landed the job -- essentially the same job he holds today.
Alan J. Dombrow
Born: Brooklyn, N.Y.,
Nov. 5, 1944 Home: Springfield, Va. Education: Never graduated from college, but earned 135 credits at three universities Title: National bank examiner, compliance management Experience: Last two decades in current job; national bank examiner 1973-78; Bank of America 1969-72 Interest: Computers, movies, step aerobics Most memorable experience: Meeting Judy Garland at Carnegie Hall in the early '60s Family: Wife, Susan, an art and photography teacher; daughter, Jennifer, an ensign in the Navy; and son, Michael, a high-school senior