Eugene Ludwig

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Eugene Ludwig
Ludwig eugene.jpg
Portrait of Eugene Ludwig
Comptroller of the Currency
In office
Preceded by Robert L. Clarke
Succeeded by John D. Hawke, Jr.
Personal details
Born (1946-04-11) April 11, 1946 (age 71)
York, Pennsylvania, United States
Nationality American
Spouse(s) Dr. Carol Ludwig
Children 3
Alma mater Haverford College
Oxford University
Yale University
Occupation Founder and CEO of
Promontory Financial Group
Former US Comptroller of the Currency

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, a global financial services advisory firm. He is also the former vice chair at Bankers Trust of Deutsche Bank, and from 1993 to 1998 served as President Clinton's Comptroller of the Currency.

Personal life[edit]

Ludwig was born in Brooklyn[1], N.Y., to Jacob S. and Louise R. Ludwig.[2] He was raised in York, Pennsylvania,[3] attending public schools.[4] His father was a country doctor who took his son with him to get his first office loan.[5] His mother was a former Broadway chorus girl.[6] His younger brother Ken Ludwig became an award-winning playwright.[7]

Ludwig received his undergraduate degree magna cum laude from Haverford College in 1968.[3] He received a scholarship to Oxford University, where he earned a Masters of Arts as a Keasbey Fellow; and he holds a law degree from Yale, where he was editor of the Yale Law Journal and chairman of Yale Legislative Services.[3]

Ludwig lives in Washington, D.C. He is married to Dr. Carol Ludwig, and they have three children.

Legal career[edit]

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.[8] Ludwig called the practice "consumer deception."[8]

Government service[edit]

In 1993, President Bill Clinton selected Ludwig to become the 27th Comptroller of the Currency. 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. He improved safety and soundness supervision through adoption of "supervision by risk",[9] an approach that has been adopted by many other supervisory agencies.[10] He also led the government's efforts to reform the Community Reinvestment Act and more vigorously enforce the fair lending laws.[10]

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."[11]

Business career[edit]

Bankers Trust / Deutsche Bank[edit]

Ludwig served as vice chairman of Bankers Trust/Deutsche Bank from April 1998[12] to December 31, 1999.[13]

Promontory Financial Group[edit]

In 2000, Ludwig founded Promontory Financial Group, a global financial services consulting firm, of which he is 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,"[14] recommending improved compliance and management measures which helped the bank regain its footing.[15] In 2007, after Ludwig advised Countrywide Financial, 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."[16] Business Week reported that Promontory has also advised PNC Financial Services Group, Riggs National Bank, and Citigroup, and helped clean up abuses at AIG.[15] In 2008, Bloomberg reported that Morgan Stanley had become a client of Ludwig's.[17]


Ludwig has written numerous articles on banking and finance for scholarly journals and publications and has been a guest lecturer at Yale and Harvard law schools and Georgetown University's International Law Institute.[18] In 2008, he 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.[19] In June 2010, Ludwig authored a piece in the New York Times observing that although Congress had passed financial regulatory reform, the real work of filling in the details would now fall to the regulators.[20] "If the New Deal is credited with creating the regulatory agencies," Ludwig wrote, "this bill will be remembered for super-charging their authority."[20] In December 2011, Ludwig authored an article in "The New York Times" advocating a permanent cut in the payroll tax as a first step toward fundamental tax reform.[21] In 2012, Ludwig and Paul A. Volcker co-authored a Wall Street Journal essay calling for accounting reform to ensure that banks could build adequate loan loss reserves well before losses are realized.[22]

In 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.[23] Ludwig is a champion of the idea that universities should create more courses and degrees for financial services supervision and regulation.[24]


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