WASHINGTON - The Office of the Comptroller of the Currency has levied $11,000 in civil penalties against a former top executive and another employee of the failed National Bank of Washington.

W. Thomas Fleming, who was president of the bank that was once one of the largest in the nation's capital, consented to pay a $10,000 penalty.

Thelma E. Pollard, a trader in the bank's treasury services division, agreed to a $1,000 penalty and to not work in a federally insured institution for two years.

Ms. Pollard was also banned for life from selling securities or deposit instruments over $100,000; from any job that involves making investment decisions for trust accounts; and from policymaking functions or management positions.

Neither admitted wrongdoing.

Lending Limit at Issue

The Comptroller's office alleged that Mr. Fleming violated National Bank of Washington's legal lending limit by making $61 million loans to a bank affiliate in 1989 and 1990.

Ms. Pollard allegedly made $4 million in illegal transfers of customer funds from insured deposit accounts into uninsured Washington Bancorp. commercial paper, without customer consent.

The bank, which had $1.6 billion in assets, failed on Aug. 13, 1990. In the ensuing weeks, customers filed more than a dozen lawsuits alleging that the bank had transferred their funds into the parent company's high-risk commercial paper without telling them the investments were not federally insured.

Last month, the Justice Department filed a $140 million civil suit against a loan officer and 10 former directors ib behalf of the Federal Deposit Insurance Corp.

Luther H. Hodges Jr., the bank's politically well-connected chairman and chief executive, was named as a defendant in the lawsuit.

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