It may never be publicly known who leaked the confidential examiner's report on Citicorp's mortgage unit, but industry observers suspect it was a dissatisfied bank employee.

A motive would not be hard to established. Morale at the nation's biggest banking company has deteriorated badly because of aggressive cost cutting and thousands of layoffs. Many employees remain uncertain about their future.

"It's clear someone who is disaffected [at Citicorp] has made good use of a Xerox machine," said Richard L. Huber, vice chairman at Continental Bank Corp. A Citicorp spokesman declined to speculate on the source of the leak.

Another Scenario

There was also some speculation that the document was leaked by a mid-level regulator from the Office of the Comptroller of the Currency. One analyst said that someone at the OCC might have been dissatisfied with Citicorp's response to the agency's exam and wanted to apply public pressure.

But Frank Maguire, senior deputy comptroller, said the agency was confident that none of its employees leaked the report. "There is evidence on the document that the reporters obtained that would lead us to believe that it did not come from within the OCC," Mr. Maguire said.

For example, Mr. Maguire said, reporters questioning OCC officials about the report read from written remarks on their copies - comments he said were not included on the official version OCC gave Citicorp.

Justice Dept. Probe Sought

The OCC has asked the Justice Department to investigate the leak, Mr. Maguire said. Justice had not made a decision whether to press the case on Thursday.

In addition to the possible Justice probe, the OCC will investigate internally, as Citicorp is expected to do. But the agency is not optimistic that it will be able to identify who leaked the document.

"It is always very difficult to track down where these leaks come from," former Comptroller Robert L. Clarke said in an interview Thursday.

Indeed, even the reporters who wrote about the confidential report apparently do not know where it came from.

Michael Quint, the reporter who wrote the story for The New York Times, said the report was hand-delivered in an unmarked envelope. He said he didn't know who sent it and wouldn't speculate.

The Wall Street Journal would not comment.

Releasing confidential information about a bank is illegal. If the leak came from Citicorp, the employee faces a $10,000 fine and/or 10 years in jail, according to OCC deputy chief counsel Robert B. Serino. An OCC employee found quilty of releasing the report would be fired and could face a $5,000 fine and a one-year jail term. Both crimes are felonies.

No one has ever been successfully prosecuted for leaking a regulatory report on a bank, according to OCC spokeswoman Lee Cross. But such information has made its way into newspapers before. In January 1976, The Washington Post published critical exam reports on Citibank and Chase Manhattan Bank.

"We never did find out who did it, though there was a strong suspicion that it came from the government," recalled Paul Homan, a former OCC top official who is now running First Florida Banks, Tampa, Fla.

In June 1985, the Atlanta Constitution published details on Calhoun First National Bank, one of the banks owned by Bert Lance. Mr. Lance's extensive attempts to discover who released the report failed.

Copies to Top People Only

The OCC only gave a few copies to senior management at Citibank, according to several officials. The agency has no safeguards to prevent leaks, such as customizing each copy.

But Mr. Clarke noted: "The system must work pretty well because it happens so infrequently."

Although Citicorp would not comment on how it controls access to its exam documents, Mr. Huber, who is a former Citicorp executive, guessed that Citicorp, like Continental, strictly controlled access to them.

He estimated that in Citicorp's case only about 20 executives saw it. But he added that a host of secretaries and clerks also saw it.

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