Eugene Ludwig

Eugene A. "Gene" Ludwig (born April 11, 1946) is an American business leader and expert on banking regulation, risk management, and fiscal policy. He is the founder and CEO of Promontory Financial Group, an IBM Company, a global risk management and regulatory compliance consulting firm focusing primarily on the financial services industry. He is also the former vice chairman of Bankers Trust and Deutsche Bank, and from 1993 to 1998 served as President Clinton's Comptroller of the Currency.

Gene Ludwig
Comptroller of the Currency
In office 1993–1998
President	Bill Clinton
Preceded by	Robert L. Clarke
Succeeded by	John D. Hawke Jr.
Personal details
Born	(1946-04-11) April 11, 1946 New York City, New York, U.S.
Spouse(s)	Carol Ludwig
Children	3
Education	Haverford College (BA) New College, Oxford (MA) Yale University (JD)

Personal life

Ludwig was born in Brooklyn, New York,[1] to Jacob S. and Louise Rabiner Ludwig.[2] He was raised in York, Pennsylvania, attending public schools.[3] His father was a country doctor who took his son with him to get his first office loan.[4] His mother was a former Broadway chorus girl.[5] His younger brother Ken Ludwig is an award-winning playwright.[6] "Dear Jack, Dear Louise," a play by Ludwig's brother based on their parents' courtship during World War II, opened at Arena Stage in December 2019.[7]

Ludwig received his undergraduate degree magna cum laude from Haverford College in 1968 and was initiated into Phi Beta Kappa. He received a scholarship to Oxford University, where he studied philosophy, politics and economics at New College and earned a Masters of Arts as a Keasbey Fellow. He holds a J.D. degree from Yale Law School, where he was an editor of the Yale Law Journal and president of Yale Legislative Services.[8] He is a Wykeham Fellow at New College, Oxford.[9] Ludwig lives in Washington, D.C. He is married to Dr. Carol Ludwig, and they have three children.

Legal career

Ludwig joined the law firm of Covington and Burling in 1973 and became a partner in 1981. He specialized in intellectual property law, banking, and international trade. In 1987, 'The New York Times' described him as a leader in the fight against gray-market goods, which are goods manufactured overseas and imported without the consent of the trademark holder. Ludwig called the practice "consumer deception."[10]

Government service

In 1993, President Bill Clinton selected Ludwig to become the 27th Comptroller of the Currency, responsible for chartering, regulating, and supervising national banks and the federal branches and agencies of foreign banks. As Comptroller, Ludwig led the agency through a period of substantial change, both within the financial marketplace as well as in the supervisory and examination practices of the agency. Ludwig took office at time of economic upheaval, following a recession that yielded a spike in bank failures and amid a credit crunch that had persisted for several years.[11] He took the lead in regulators’ 1993 initiatives to alleviate a lingering credit crunch by encouraging banks to increase lending,[12] and later described the results as “dramatic.” He said: “The credit crunch abated, the economy began to grow again and the banking industry returned to good health.”[13]

Ludwig improved safety and soundness supervision through adoption of "supervision by risk",[14] an approach that has been adopted by many other supervisory agencies.[15]

Ludwig also led President Clinton's initiatives to reform the Community Reinvestment Act and more vigorously enforce the fair lending laws.[16] In December 1993, Ludwig was singled out by then-Secretary of the Treasury Robert Rubin, who praised “his efforts to make CRA reform a reality."[17]

During five years in office, Ludwig oversaw 4,000 fair lending examinations of national banks and made 25 referrals of fair lending violations to the Department of Justice and the Department of Housing and Urban Development. Previously, there had been only one such referral to a federal agency charged with fair lending enforcement.[18]

As Comptroller, Ludwig served as a member of the Basel Committee on Bank Supervision, a director of the Federal Deposit Insurance Corporation, and a director of the Neighborhood Reinvestment Corporation.[19]

Reflecting on his service as Comptroller in April 2010, Ludwig testified before the U.S. House Subcommittee on Financial Institutions and Consumer Credit that "credit made available to low- and moderate-income Americans through CRA programs during ... the 1990s was not only transforming for low- and moderate-income communities, but it was almost without exception profitable and safe."[20]

Business career

Bankers Trust / Deutsche Bank

Ludwig served as vice chairman of Bankers Trust/Deutsche Bank from April 1998[21] to December 31, 1999.[22] During his time there, he participated in the rescue negotiations for Long-Term Capital Management, a bond-trading hedge fund that was recapitalized under the Federal Reserve’s guidance by 16 leading financial institutions to prevent its collapse.[23]

Promontory Financial Group

In 2001, Ludwig founded Promontory Financial Group, becoming its CEO and chairman. The firm gained attention when, following a $750 million trading scandal at Allied Irish Banks, Promontory produced what became known as "The Ludwig Report,"[24] recommending improved compliance and management measures which helped the bank regain its footing.[25] In 2007, after Ludwig advised Countrywide Financial, Portfolio.com wrote that "[Countrywide CEO] Angelo Mozilo is a tough character, and Ludwig is one of the few people with enough clout to persuade him that the game really was up."[26] Business Week reported that Promontory has also advised PNC Financial Services Group, Riggs National Bank, and Citigroup, and helped clean up abuses at AIG.[27] In 2008, Morgan Stanley announced that it had become a client of Ludwig's.[28]

Other business ventures

Ludwig is also co-founder and managing partner of Canapi Ventures, a venture capital firm,[29] and chairman of Promontory MortgagePath, which provides mortgage fulfillment services to financial institutions.[30][31] Promontory Interfinancial Network, a separate company that Ludwig started in 2003 with former Federal Reserve Vice Chairman Alan Blinder, was sold in 2019 to Blackstone Group.[32][33]

Notable statements and testimony

Since founding Promontory Financial Group, Ludwig has been invited to testify before Congress as an expert witness several times:

In October 2008 testimony to the Senate Banking Committee, Ludwig summarized the origins of the Financial Crisis of 2007-08: “The fundamental story of the current turmoil is relatively easy to tell. It began early in this decade with a weakening of underwriting standards for subprime mortgages in the U.S. Subprime, alt-A and other mortgage products [which] were sold to people who could not afford them and in some cases in violation of legal standards.”[34]

In February 2009, Reuters reported that Ludwig was an advisor to U.S. Senate Banking Committee Chairman Christopher Dodd and U.S. House Speaker Nancy Pelosi, as well as Republican Senator Richard Shelby, among others.[35]

In September 2009, Ludwig testified before the Senate Banking Committee and said, ‘‘we must dramatically streamline the current alphabet soup of regulators,’’ citing the burden on financial institutions of duplicative supervision, gaps between regulatory responsibilities, and regulatory arbitrage.[36]

IBM

In September 2016, IBM announced plans to acquire Promontory, citing its status as “the firm financial institutions turned to for guidance coming out of the 2008 financial crisis.” The transaction was completed in November 2016, and the firm— renamed Promontory Financial Group, an IBM Company—became a wholly owned subsidiary of IBM with Ludwig remaining at the helm.[37]

IBM, describing Promontory’s expertise in regulation, risk, and compliance as “unsurpassed,” said Promontory’s team of 600 professionals would train IBM’s Watson cognitive computing system to understand a massive volume of regulations and compliance requirements. By harnessing this information, Watson—which combines artificial intelligence with analytical software to support complex decision-making—could accelerate financial institutions’ ability to understand regulatory changes and obligations and address compliance requirements, IBM said.[38]

Cognitive computing “has the potential to vastly improve existing approaches to risk management, potentially covering everything from stress testing and capital planning to credit portfolio analysis, risk modeling, and regulatory change management,” Ludwig wrote in Investor’s Business Daily in December 2016.[39]

Ludwig stressed that artificial intelligence would complement, rather than replace, human compliance efforts.[40]

Expertise and views

Ludwig has written numerous articles on banking, finance, and economic policy for scholarly journals and publications and has been a guest lecturer at Yale and Harvard law schools and Georgetown University's International Law Institute.[41] A theme in Ludwig's speeches and writings has been his conviction that the economic challenges confronting lower- and middle-income Americans are growing urgent. He has noted that real-wage stagnation, combined with dramatic surges in the costs of basics such as education, housing, health care and food, have created a situation in which middle-income households by 2014 were spending 78% of their budgets on basic needs.[42] He has voiced skepticism about strong economic indicators such as gross domestic product and jobs numbers, arguing in a CNBC op-ed in July 2018 that common measures of economic health mask significant and growing disparities between the wealthiest Americans and those in lower- and middle-income brackets.[43] He has also raised concern about what he has described as poorly conceived limits on policymakers' ability to respond forcefully to a severe economic downturn.[44]

In 2008, Ludwig co-authored an essay in The Wall Street Journal with former Federal Reserve Chairman Paul A. Volcker and former U.S. Treasury Secretary Nicholas F. Brady calling for a resurrection of the Resolution Trust Corporation to help deal with the financial crisis.[45] The op-ed was widely discussed and cited, capturing the interest of, among others, then-Treasury Secretary Hank Paulson as he explored solutions to the rapidly unfolding financial crisis.[46]

Author

Date	Title	Publication	Topic
May 28, 2020	"How the Fed’s Rescue Program Is Worsening Inequality"	Politico	Analyzed how federal intervention programs to deal with the Covid-19 pandemic are exacerbating inequality. They asserted that by intervening in the high-yield or junk bond market, “Washington is backstopping loans that are predominately purchased by wealthy investors.” (Co-authored with Sarah Bloom Raskin.)[47]
March 6, 2020	"A Tax Cut Democrats and Republicans Could Agree On? The Payroll Levy"	Washington Post	Argued that both parties have a good reason to get behind an effort to free middle- and working-class families from a disproportionate tax burden. Eliminating the payroll tax could help stimulate the economy, and given the coronavirus outbreak, the time is right.[48]
February 18, 2020	"Lessons for Bankers from Disasters that Didn't Have to Be"	American Banker	Called on companies to own up to mistakes and problems in order to maintain a strong company culture that is focused on regulation, risk and transparency for maintaining a strong company culture. (Co-authored with Susan Krause Bell and Wayne Rushton.) [49]
January 31, 2020	"CECL Is a Real Threat to the Financial System"	American Banker	Argued that the Financial Accounting Standards Board has been incorrect in how it limits a bank’s allowance for loan and lease losses and called for reform. [50]
July 11, 2019	"Payroll Tax Has Become a Monster. It Needs to Be Replaced"	Newsweek	Called for replacing the payroll tax with non-labor taxes, arguing that the payroll tax had become "the biggest tax 80 percent of Americans pay."[51]
June 20, 2019	"The Key to Rightsizing Regulation"	American Banker	Advocated creation of a "National Institute of Regulation" to examine regulatory effectiveness and efficiency.[52]
June 11, 2019	"U.S. Regulators Ill Prepared for Next Downturn"	Financial Times	Urged Congress to restore supervisory powers that were stripped away after the 2008 financial crisis. [53]
May 15, 2019	"Rosy Economic Data Belie a Harsh Reality for Many Americans	The Hill	Argued that lower- and middle-income Americans have not shared in economic advances for decades, and urged policymakers to focus on making community college affordable, promoting financial literacy, and creating more flexible ways for people to work their way out of delinquent debts.[54]
October 31, 2018	"Warning: The Deregulatory Mood Can't Last Forever"	American Banker	Identified five "good government" reforms that the financial services industry should pursue: Elimination of regulatory duplication, requiring fair rights of appeal in the supervisory process, promoting innovation in banking, improving regulatory effectiveness, and modernizing finance for low-income groups.[55]
July 6, 2018	"Regulators Have Their Eye on AI"	American Banker	Described artificial intelligence as "an increasingly important tool in finance" that has "the potential to create regulatory problems if it isn’t used carefully."[56]
April 4, 2018	"America's Economic Challenges"	Banking Exchange	Examined decline in economic opportunities for lower- and middle-class Americans and argued that "economic reality in America is a widening chasm between the wealthy and everyone else, and fueling disquiet in those who struggle economically. [57]
February 9, 2018	"Getting Ahead of Risk Involves Asking the Right Questions"	American Banker	Focused on how to identify specific ways institutions are vulnerable to risk and raised concern about "groupthink that dismisses a systemic event in the foreseeable future."[58]
December 20, 2017	"Bankers Should Resolve to Be More Paranoid in 2018"	American Banker	Warned the financial services industry of the risk of economic downturn and cited concern that "a major tail event that will shock the financial indusry is likely in the foreseeable future." [59]
October 1, 2016	"How America Can Get Out of Its Economic Swamp"	Time	Decried bias in the federal budget process against crucial spending, particularly for infrastructure, education and research. Advocated for the creation of a federal capital budget to provide a framework for long-term expenditures, noting that this approach is used in the private sector and by most state governments.[60]
March 15, 2016	"Unregulated Shadow Banks Are a Ticking Time Bomb"	American Banker	Critiqued the approach of strictly regulating banks while only loosely regulating nonbank financial institutions, or "shadow banks."[61]
November 17, 2012	"Banks Need Long-Term Rainy Day Funds"	The Wall Street Journal	Called for accounting reform to ensure that banks could build adequate loan loss reserves well before losses are realized. (Co-authored with Paul A. Volcker)[62]
December 7, 2011	"Why the Fight Over the Payroll Tax Matters"	The New York Times	Advocated a permanent cut in the payroll tax as a first step toward fundamental tax reform.[63]
June 25, 2010	"Another View: Now It's Up to the Regulators"	The New York Times	Observed that although Congress had passed financial regulatory reform, the real work of filling in the details would now fall to the regulators. "If the New Deal is credited with creating the regulatory agencies, this bill will be remembered for super-charging their authority."[64]
February 2009	“The Community Reinvestment Act: Past Successes and Future Opportunities”	“Revisiting the CRA: Perspectives on the Future of the Community Reinvestment Act,” by the Federal Reserve Banks of Boston and San Francisco	Retrospective and analysis of the Community Reinvestment Act. (Co-authored with James Kamihachi and Laura Toh)[65]
November 19, 2008	"Don't Junk the U.S. Auto Industry	Reuters	Argued that providing government aid to the three major U.S. automakers would be far more effective than allowing them to go bankrupt.[66]
September 17, 2008	"Resurrect the Resolution Trust Corp.	The Wall Street Journal	Called for recreation of the Resolution Trust Corporation to help deal with the financial crisis. (Co-authored with former Federal Reserve Chairman Paul A. Volcker and former U.S. Treasury Secretary Nicholas F. Brady.[67]

Selected speeches

Date	Speech	Sponsor/Event/Venue
June 5, 2019	Keynote address[68]	World Bank, 9th Annual International Conference on Policy Challenges for the Financial Sector, Washington, D.C.
June 4, 2019	Keynote address[69]	Community Development Bankers Association 2019 Peer Forum, Washington, D.C.
March 11, 2019	Moderator, “Globalization vs. Fragmentation”[70]	Institute of International Bankers Annual Washington Conference, Washington D.C.
October 31, 2013	“Supervision in a Time of Change”[71]	The George Washington University Center for Law, Economics & Finance. Washington, D.C.
October 25, 2012	Panel, "Reformed: Has Financial Regulation Saved the System?"[72]	The Economist 2012 Buttonwood Gathering, New York
May 11, 2012	Keynote address, “Faith, Judgment, and Rigor: The Role of Capital and Supervision in PostCrisis Financial Regulation”[73]	Federal Reserve Bank of Chicago 48th Annual Conference on Bank Structure and Competition
February 19, 2010	"Extending Credit to Lower Income Americans Safely and Fairly"[74]	Joint Center for Housing Studies of Harvard UniversityInternational Conference on Banking Supervision, Brussels
September 25, 2008	William Taylor Memorial Lecture, "We Must Have Supervision and Regulation"[75]	International Conference on Banking Supervision, Brussels
September 23, 2008	Annual Hagedorn Lecture on Corporate Social Responsibility[76]	Adelphi University, Garden City, N.Y.

Interviews

Date	Topic/Quote	Venue
August 14, 2019	Podcast: “Artificial Intelligence, Community Banks, and the Compliance Jobs of the Future."	ABA Banking Journal interview with Evan Sparks[77]
January 1, 2017	Regulatory simplification: “Our regulatory system is far too complex,” he said in a January 2017 radio interview. “Too many agencies create a great deal of burden with no particular benefit. It is an artifact of history, not logic, and it needs to be changed.”	Bloomberg Radio interview with Arthur Levitt
May 29, 2013	Long-term regulatory trends (video)[78]	Interview with Professor Jeffrey Garten, Yale School of Management
September 2010	Expert testimony on causes of the financial crisis of 2007-8[79]	Financial Crisis Inquiry Commission

Civic activities and honors

Ludwig is president of The Ludwig Family Foundation Inc., a charitable organization that focuses on improving education, alleviating poverty, and supporting medical research and the arts.[80]

He is a long-time member of the board of directors of the National Academy Foundation, a New York-based nonprofit that helps prepare low- and moderate-income students for college and careers.[81] Ludwig has also endowed several funds and programs, including the Ludwig Fund for the Humanities at New College, Oxford[82]; the Eugene and Carol Ludwig Center for Community & Economic Development at Yale Law School [83]; and the Ludwig Fund for Community Development at Haverford College.[84]

Ludwig has received numerous awards for excellence and leadership, including the BritishAmerican Business Entrepreneurship Award (2010),[85] National Academy Foundation Leadership Award (2011),[86], Simeon E. Baldwin Award, presented by the Yale Law School Center for the Study of Corporate Law (2011)[87], the Foreign Policy Association Medal (2014), [88] and the Jill Chaifetz Award presented by Advocates for Children (2014.)[89]

References

1. “Nomination of Eugene Allan Ludwig to Be Comptroller of the Currency for a Term of Five Years,” U.S. Senate Hearing 103-92, before the Committee on Banking, Housing, and Urban Affairs, March 31, 1993
2. Washington Post obituary, "Louise R. Ludwig, Businesswoman," August 28, 1998
3. U.S. Senate Hearing 103-92, nomination hearing record, 1993, page 1
4. United States Banker cover story, "Why Eugene Ludwig Makes Bankers Nervous, August 1993
5. The Washington Post, "Playwright Ken Ludwig's Childhood Dream"
6. Ken Ludwig website
7. Found at: https://www.arenastage.org/tickets/1920-season/dear-jack-dear-louise/
8. U.S. Senate Hearing 103-92, nomination hearing record, 1993, pages 2, 43
9. “Emeritus, Honorary and Wykeham Fellows,” website of New College, Oxford. Found at: http://www.new.ox.ac.uk/emeritus-honorary-and-wykeham-fellows
10. "Businessmen Bemoan Losses to Gray Market, The New York Times, May 3, 1987. Found at: https://www.nytimes.com/1987/05/03/nyregion/businessmen-bemoan-losses-to-gray-market.html
11. Michael Quint, “Quicksand for Banks,” The New York Times, March 27, 1990.
12. Jerry Knight, “Regulators Offer Steps to Ease Bank Lending,” The Washington Post, June 11, 1993
13. Resignation letter of Eugene A. Ludwig to President Clinton, January 15, 1998. Found at: https://www.occ.gov/static/news-issuances/news-releases/1998/nr-occ-1998-5.pdf
14. OCC Press Release, Supervision by Risk
15. Official biography, "Eugene A. Ludwig, Comptroller of the Currency, 1993 to 1998," Office of the Comptroller of the Currency. Found at: https://www.occ.gov/about/who-we-are/leadership/past-comptrollers/comptroller-eugene-ludwig.html
16. Official biography, "Eugene A. Ludwig, Comptroller of the Currency, 1993 to 1998," Office of the Comptroller of the Currency
17. White House Press Briefing by Secretary of the Treasury, Lloyd Bentsen, Robert Rubin, Assistant to the President for Economic Policy and Eugene Ludwig, Comptroller of the Currency, December 8, 1993. Found at: http://www.presidency.ucsb.edu/ws/index.php?pid=60001
18. Testimony of Eugene A. Ludwig before Re. Maxine Waters' "Forum on Community Reinvestment and Access to Credit: California’s Challenge," Los Angeles, January 12, 1998. Found in: OCC Quarterly Journal, Vol. 17 , No. 2, June 1998, page 28.
19. https://www.americanbanker.com/author/eugene-a-ludwig
20. Testimony of Eugene A. Ludwig before the Subcommittee on Financial Institutions and Consumer Credit of the House Financial Services Committee, April 15, 2010, page 1. Found at: https://financialservices.house.gov/media/file/hearings/111/04_15_10_ludwig_house_testimony.pdf
21. Bill McConnell, "Ludwig Joining Bankers Trust as a Vice Chairman," American Banker, April 22, 1998
22. "Ludwig, Partners Organizing Investment Fund," American Banker, January 14, 2000
23. Eugene A. Ludwig,"Unregulated Shadow Banks Are a Ticking Time Bomb,” American Banker, March 15, 2016
24. The Irish Times, The Ludwig Report
25. "Countrywide Under Promontory Review," Business Week, November 28, 2007
26. Portfolio.com, "How Gene Ludwig Forced the Countrywide Sale"
27. "Countrywide Under Promontory Review," Business Week, November 28, 2007
28. Morgan Stanley news release, "Morgan Stanley Hires Promontory Financial Group to Advise on Banking Holding Company Conversion," September 25, 2008. Found at: https://www.morganstanley.com/press-releases/morgan-stanley-hires-promontory-financial-group-to-advise-on-bank-holding-company-conversion_6958
29. Penny Crossman, “Gene Ludwig, Chip Mahan Launch $545M Fund for Bank-Friendly Fintechs,” American Banker, January 22, 2020. Found at: https://www.americanbanker.com/news/gene-ludwig-chip-mahan-launch-545m-fund-for-bank-friendly-fintechs
30. ”Promontory MortgagePath Consolidates into One Entity,” National Mortgage Professional Magazine, January 9, 2020. Found at: https://nationalmortgageprofessional.com/news/73442/promontory-mortgagepath-consolidates-entity
31. LinkedIn profile of Gene Ludwig. Found at https://www.linkedin.com/in/gene-ludwig/
32. Rob Blackwell, “New Pitch: Deposit Insurance Sharing,” American Banker, January 21, 2003
33. Luisa Beltran, "Blackstone to Scoop Up Promontory Interfinancial," PE Hub, September 17, 2019. Subscription required.
34. U.S. Senate Report 111-176, testimony of Eugene A. Ludwig before the Committee on Banking, Housing and Urban Affairs on October 16, 2008.
35. Reuters, Bank Plan Could Shorten the Crisis: Ludwig
36. U.S. Senate Report 111-176, testimony of Eugene A. Ludwig before the Committee on Banking, Housing and Urban Affairs on September 29, 2009.
37. IBM news release, “IBM announces planned acquisition of Promontory to transform regulatory compliance with Watson,” September 29, 2016.
38. IBM news release, September 29, 2016.
39. Eugene Ludwig, “Commentary: A Major Technological Turning Point for Finance,” Investor’s Business Daily, December 8, 2016
40. Colin Wilhelm, “Is AI the key to regulatory compliance?” Politico Pro, December 23, 2016
41. Ludwig speeches
42. "America's Economic Challenges," Banking Exchange, April 4, 2018
43. "Strong GDP and Jobs Numbers Don't Tell the Whole Story About America's Economic Reality," CNBC.com, July 16, 2018. Found at: https://www.cnbc.com/2018/07/10/strong-gdp-and-jobs-numbers-dont-tell-the-whole-story-about-americas.html
44. "US Regulators Ill Prepared for Next Downturn," Financial Times, June 11, 2019, found at https://www.ft.com/content/881cdd9a-7587-11e9-b0ec-7dff87b9a4a2
45. Brady, Ludwig, and Volcker, "Resurrect the Resolution Trust Corp.," The Wall Street Journal, September 17, 2008
46. Andrew Ross Sorkin, "Too Big to Fail: The Inside Story of How Washington and Wall Street Fought to Save the Financial System--and Themselves," page 429, Viking Press, 2009
47. “How the Fed’s Rescue Program Is Worsening Inequality,” Politico, May 28, 2020. Found at: https://www.politico.com/news/agenda/2020/05/28/how-the-feds-rescue-program-is-worsening-inequality-287379
48. "A Tax Cut Democrats and Republicans Could Agree On? The Payroll Levy," Washington Post, March 6, 2020. Found at: https://www.washingtonpost.com/outlook/a-tax-cut-democrats-and-republicans-could-agree-on-the-payroll-levy/2020/03/06/08a9d2ae-5711-11ea-9b35-def5a027d470_story.html
49. "Lessons for Bankers from Disasters that Didn't Have to Be," American Banker, February 18, 2020. Found at: https://www.americanbanker.com/opinion/lessons-for-bankers-from-disasters-that-didnt-have-to-be
50. "CECL Is a Real Threat to the Financial System," American Banker, January 31, 2020. Found at: https://www.americanbanker.com/opinion/cecl-is-a-real-threat-to-the-financial-system
51. "Payroll Tax Has Become a Monster. It Needs to Be Replaced," Newsweek, July 11, 2019. Found at: https://www.newsweek.com/payroll-tax-monster-needs-replacing-2020-1448767
52. "The Key to Rightsizing Regulation," American Banker, June 20, 2019. Found at: https://www.americanbanker.com/opinion/the-key-to-rightsizing-regulation
53. "U.S. Regulators Ill Prepared for Next Downturn," Financial Times, June 11, 2019. Found at: https://www.ft.com/content/881cdd9a-7587-11e9-b0ec-7dff87b9a4a2
54. "Rosy economic data belies a harsh reality for many Americans," The Hill, May 15, 2019. Found at: https://thehill.com/opinion/finance/443794-rosy-economic-data-obscures-the-harsh-reality-for-many-americans
55. "Warning: The Deregulatory Mood Can't Last Forever," American Banker Found at: https://www.americanbanker.com/opinion/warning-the-deregulatory-mood-cant-last-forever
56. "Regulators Have Their Eye on AI," American Banker, July 6, 2018. Found at: https://www.americanbanker.com/opinion/regulators-have-their-eye-on-ai
57. "America's Economic Challenges," BankingExchange, April 4, 2018, http://www.bankingexchange.com/blogs-3/unconventional-wisdom/item/7475-america-s-economic-challenges?Itemid=639
58. "Getting Ahead of Risk Involves Asking the Right Questions," American Banker, February 9, 2018.
59. "Bankers Should Resolve to Be More Paranoid in 2018," American Banker, December 20, 2017
60. Eugene Ludwig, “How America Can Get Out of Its Economic Swamp,” Time, October 3, 2016
61. Eugene Ludwig, “Unregulated shadow banks are a ticking time bomb,” American Banker, March 15, 2016
62. Eugene A. Ludwig and Paul A. Volcker, "Banks Need Long-Term Rainy Day Funds," The Wall Street Journal, November 17, 2012
63. Eugene Ludwig, "Why the Fight Over the Payroll Tax Matters," The New York Times, December 7, 2011
64. Eugene Ludwig, "Another View; Now It's Up to the Regulators," The New York Times, June 25, 2010
65. Found at: http://www.frbsf.org/community-development/files/cra_past_successes_future_opportunities1.pdf
66. Eugene Ludwig, "Don't Junk the U.S. Auto Industry," Reuters, November 19, 2008 Found at: http://blogs.reuters.com/great-debate/2008/11/19/dont-junk-the-us-auto-industry/
67. Brady, Ludwig, and Volcker, "Resurrect the Resolution Trust Corp.," The Wall Street Journal, September 17, 2008
68. http://pubdocs.worldbank.org/en/367011560353015517/Eugene-Ludwig-CEO-Promontory-Keynote-Address.pdf
69. http://www.cdbanks.org/2019-peer-forum
70. https://cdn.ymaws.com/www.iib.org/resource/resmgr/2019awc/2019AWCProgram22.pdf
71. https://mediarelations.gwu.edu/fifth-annual-financial-regulatory-reform-symposium-%E2%80%9C-road-traveled-assessing-dodd-frank-five-years
72. The Economist You Tube channel, https://www.youtube.com/watch?v=dRC8msd_Ats
73. https://www.chicagofed.org/events/2012/bank-structure-conference
74. https://www.americanprogress.org/issues/economy/news/2010/04/01/7672/extending-credit-to-lower-income-americans-safely-and-fairly/
75. Found at: http://group30.org/images/uploads/publications/G30_LessonsLearned2008FinancialCrisis.pdf
76. Adelphi University Magazine, Spring 2019, page 7. Found at:https://issuu.com/adelphiuniversity/docs/adelphi-mag-spring-2009/7
77. https://bankingjournal.aba.com/2019/08/podcast-ai-community-banks-and-the-compliance-jobs-of-the-future/
78. https://som.yale.edu/blog/interview-with-eugene-ludwig
79. Found at: http://fcic.law.stanford.edu/interviews/view/52
80. Found at: https://fconline.foundationcenter.org/grantmaker-profile/?key=LUDW016&view_format=compact
81. Found at: http://naf.org/about/board-of-directors
82. Found at: http://users.ox.ac.uk/~sfop0114/nclm4/nclm4.html
83. Found at: https://law.yale.edu/studying-law-yale/clinical-and-experiential-learning/our-clinics/ludwig-center-community-economic-development
84. "Haverford College Endowed Internships," found at: https://docs.google.com/document/d/1FGCLiqRBtS4oXxUZGVBHGTopC867qlLdDQgLS2WT7iA/edit
85. http://www.promontory.com/Bios.aspx?id=1022
86. "Leadership Awards Abound,” New York Social Diary, June 13, 2011. Found at: http://www.newyorksocialdiary.com/party-pictures/2011/leadership-awards-abound
87. http://ccl.yale.edu/simeon-e-baldwin-award/recipient-list
88. Victoria Finkle, “Promontory’s Ludwig Wins Foreign Policy Medal,” American Banker, February 28, 2014.
89. Found at: http://www.advocatesforchildren.org/sites/default/files/on_page/NP_sb_journal_2014.pdf?pt=1

External links

• Appearances on C-SPAN

Government offices
Preceded by Robert L. Clarke	Comptroller of the Currency 1993–1998	Succeeded by John D. Hawke, Jr.