Because every successful regulator needs a smart lawyer, Comptroller of the Currency Eugene A. Ludwig hired Julie L. Williams.
After three years as the comptroller's chief counsel, Ms. Williams gets almost as much credit as Mr. Ludwig for sprucing up the national bank charter.
Say "Gene and Julie," and everyone knows who you are talking about.
"If Gene is the OCC's architect, then Julie is the master builder," says Steven Bennett, general counsel for Banc One Corp. in Columbus, Ohio.
Rulings written by the meticulous Ms. Williams have markedly broadened national bank powers-and with the authority of the law. Four times the Comptroller's Office has been sued, and four times the agency has scored 9- 0 Supreme Court victories.
"If an agency wins that many unanimous cases, you would assume the chief legal officer is responsible," says H. Rodgin Cohen, a partner with Sullivan & Cromwell. "Everything I know about Julie confirms that. She shaped the strategy and thinking behind those cases."
"None of the orders she has issued can be accused of being based on fluff legal analyses," says Lawrence Baxter, senior vice president at Wachovia Corp. "There has always been careful legal underpinning for everything the OCC does, but her thoroughness is truly remarkable."
Take the landmark operating subsidiary rule that took effect Dec. 31. Ms. Williams marshalled several OCC units to work on the 43-page rule, which opened the door for national bank units to offer products and services off-limits for the parent bank. It took two years to finalize the regulation, in part because of the extensive legal research that stands behind it.
"There was a lot to do," Ms. Williams, 46, said in a recent interview. "We were writing and editing various backup analyses and legal opinions. We knew there was going to be a lot of interest in this rule, and we had to be prepared to answer a lot of questions."
Her clout is belied by her subdued demeanor and soft, low voice.
"If you're in a group of more than three people, you better be darn close to her to hear what she has to say," said James McLaughlin, director of regulatory and trust affairs for the American Bankers Association.
As one might expect from her calm exterior, she does not get aggravated easily.
"I rarely get upset," she said. "I'm a relatively low-key person personality-wise, but I'm also relatively intense in my desire for quality work."
Indeed, she said the only thing that really bugs her is a job not well done.
She returns staffers' work with a note penned in turquoise ink. "When you're sending notes off to folks that have piles of paper, they tend to notice that color," she said.
Even when she is in her boss' shadow, Ms. Williams' influence is obvious.
At a May 1 hearing, as Mr. Ludwig was being tongue-lashed by Senate Banking Committee Chairman Alfonse M. D'Amato, Ms. Williams was furiously scribbling on shreds of paper behind him. She placed the notes in front of the comptroller, whose eyes flitted down to read her counsel as Sen. D'Amato fired off questions.
"Julie and I very much have the classic lawyer-client relationship," Mr. Ludwig said in a recent interview. "I have tremendous faith in her legal judgment."
But Ms. Williams' role has extended far beyond offering legal counsel. For example, she has reached out to industry groups that traditionally have opposed the comptroller's positions such as the National Association of Insurance Commissioners.
When national banks began to move into the insurance sales business, Ms. Williams said she realized the importance of working with the 50 state insurance regulators.
While the OCC has maintained that state insurance laws must not discriminate against banks, the agency has conceded that states have the power to implement consumer protections and licensing rules.
"It was a very important, threshold policy judgment," Ms. Williams said. "We needed to embark on an unprecedented dialogue and getting-to-know-you and trust-building process between two different sides that really haven't talked before.
"It's been very exciting, but also very difficult," she added.
Elizabeth R. Costle, Vermont's insurance commissioner, credited Ms. Williams with doing the best possible job in a tough situation.
"She has lessened an inevitable tension and set up a good communication line," Ms. Costle said. "We don't necessarily agree with everything that is being communicated, but I'd say her greatest accomplishment is opening the door to us."
Ms. Williams stepped into banking issues in 1975 after graduating at the top of her class at the Antioch School of Law here. She joined Fried, Frank, Harris, Shriver & Kampelman to work on securities and Glass-Steagall Act issues.
"The irony is that I spent a fair amount of my time representing the Investment Company Institute, which sued this agency, the Fed, and the FDIC constantly over letting banks into the securities industry," Ms. Williams said with a grin.
In 1983, Ms. Williams joined the Federal Home Loan Bank Board as an associate general counsel. By 1986, she had been named deputy chief counsel, a position she held through the thrift crisis.
The main lesson she learned was "to trust my instincts about right and wrong, regardless of external pressures from the industry," she said.
"I was confronted with folks like Charlie Keating wanting to do certain things, and I found myself saying 'No' to those things."
Mr. Ludwig lured Ms. Williams to the OCC in May 1993.
"Gene and I had a really nice talk, and a couple of weeks later he called to offer me the deputy chief counsel position," she said. "I did the obligatory think-about-it and called him back the next day." She was named chief counsel a year later, when her predecessor Bill Bowden left the agency.
Mr. Ludwig originally brought her on board to do a top-to-bottom review of national bank rules. She had undertaken a similar project at the thrift agency, but on a much smaller scale. When she finished the project in late 1996, the agency had pared, simplified, and rewritten 29 of its rulebook's 35 parts.
Today, Ms. Williams has moved on to what she describes as the logical next step: making sure that all the changes were for the better.
To accomplish this, Ms. Williams has been handing out questionnaires to bankers at "meet the comptroller" gatherings around the country. In addition, the Comptroller's Office is conducting focus groups with bankers.
"Having gone through such a long effort to try to revise regulations, it is an obvious complement to turn around and see whether we are having the impact we had intended," Ms. Williams said.
She said the OCC will take stock of its findings at the end of the year, but added that so far, the results are looking pretty good.
"My sense-and it is purely anecdotal-is that we are getting pretty positive feedback."
