WASHINGTON - American bankers think they've got it tough, coping with this country's tangle of banking laws and regulations.

But foreign bankers doing business here are convinced that they've got it much tougher.

"It's extremely difficult for a foreigner to come to terms with the (regulatory) requirements," said Matthew King, legal adviser for the Americas for London-based Hongkong and Shanghai Banking Corp., who called the U.S. regulatory structure a "quagmire."

John Tugwell, president, CEO, and chairman of National Westminster Bancorp, the U.S. subsidiary of London's National Westminster Bank PLC, said "overreaction by regulators and legislators" to scandals involving the Bank of Credit and Commerce International and Banca Nazionale del Lavoro has burdened foreign banks here with unfair levels of scrutiny and regulation.

Mr. King and Mr. Tugwell had the opportunity to unburden themselves of these complaints at a conference here last week organized by the Office of the Comptroller of the Currency.

The Comptroller's office was a curious host in that it's not a key regulator of foreign banks. It trails the state banking departments of New York and California in the number of foreign bank licenses it has awarded, while on the national level it's the Federal Reserve that oversees foreign banks.

Still, said Jon K. Hartzell, deputy comptroller for international banking and finance, "We're very definitely in the game and staying in the game." Hence the conference.

Some regulators on hand said they sympathized with foreign bankers' complaints.

Federal Reserve Board Governor Susan M. Phillips said her agency was trying speed up its processing of applications under the Foreign Bank Supervision Enhancement Act of 1991, which requires the Fed to vet all foreign banks hoping to open U.S. branches or agencies here. She also said the law needs to be amended to make it easier for banks from developing countries to establish a presence here.

Other regulators said standardization of banking rules worldwide under the auspices of the Basel Committee on Banking Supervision would make life easier for all banks operating across national borders.

They could not agree, however, on a standardized way of saying "Basel." Comptroller of the Currency Eugene A. Ludwig went with the German pronunciation: "Bazzel."

William A. Ryback, associate director of banking supervision and regulation for the Federal Reserve, went instead with the French "Basle," pronounced "Baal."

Mr. Hartzell said they're both right. Basel is in the German-speaking part of Switzerland, but the Basel Committee, like most European-based multilateral groups, is swarming with Frenchmen.

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