V. Gerard Comizio.

V. Gerard Comizio spent eight hours over the Memorial Day weekend sweating under a blazing sun to piece together a swing set for his four children. The process was a lot like this job at the Office of Thrift Supervision.

"It was a little bit like working here," he said, "when you see instructions that were originally written in another language and have not translated well. to English. You open that box and see gigantic bags of bolts of different sizes, you know there is a challenge."

The 39-year-old Mr. Comizio faces the challenge of gauging the future of depository institutions and their regulatory structure every day in his position as a primary manager in the chief counsel's office at the OTS' business transactions division.

It's no easy task, he said. according to Mr. Comizio.

"The various statutory and regulatory paradoxes between banks and thrifts make for interesting combinations," he said. "Especially when you're in a Washington office of a federal agency, by definition the issues are more policy oriented and more complex."

Sometimes the issues seem to arise out of nowhere, he said. Still, "It's more fun than a game show."

Mr. Comizio got a little more fun than he bargained for earlier this year when the House and Senate banking committees became outraged that mutual thrift executives were showering themselves with stock at the expense of depositors as their institutions went public.

He and his staff scrambled to stop what they saw as an abuse, quickly rewriting the agency's conversion rules. "It is important that thrifts that are converting have very clear and certain guidance on how they can undertake mutual-to-stock conversions and complete them."

While the ruckus that Congress raised on stock conversions has kept the Yonkers, N.Y., native busy, he is also responsible for the legal aspects of mergers and acquisitions, thrift securities sales, and major transactions.

And in his spare time, he teaches banking law at American University's Washington College of Law and plays a mean first base on both the OTS softball teams.

Mr. Comizio is known for being a team player. He has worked closely on many corporate securities issues with OTS Northeast regional director Angelo A. Vigna, who admits to being one of Mr. Comizio's fans.

"He's pragmatic yet theoretical, but he's also responsive," said Mr. Vigna. "He's been. very instrumental in the adoption and the formulation of the OTS conversion process."

Right now, Mr. Comizio is writing rules that will help consumers identify whether investments offered at a thrift are insured.

"There are a lot of publicly expressed concerns from consumer groups that the average purchaser of mutual funds does not understand that they [the funds] are uninsured products," he said.

Next on the drawing board, he said, is a project that will involve "looking at ways, consistent with safety and soundness, to enhance the federal thrift charter. The federal thrift charter and the unitary S&L holding company structure, in terms of operational flexibility, are probably the best two charters to have in the banking business."

The OTS will also be weighing, "the questions of activities for thrift institutions and holding companies as the lines blur between insurance, securities, and banking activities, and permitting these activities while still having safe and sound standards," Mr. Comizio said.

"The agency has more experience in dealing with depository. institutions that are not subject to some of the restrictions that banks are," like Glass-Steagall, said Mr. Comizio, noting that the OTS has had safeguards on thrifts' sales' of uninsured products since 1986. "The OTS staff should be an important player on any issues related to financial services," Mr. Comizio said. "We have a lot to offer in any dialogue on any of those activities."

V. Gerard Comizio

Deputy chief counsel for business transactions

Office of Thrift Supervision

1700 G St. NW

Washington, D.C. 20552

202-906-6411

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