406-686-4282 (office)
                         406-223-6635 (cell)






406-686-4282 (office)
406-223-6635 (cell)




Brown University Ph.D., Economics, 1970
Yale University B.A., Economics, 1965



Managing Director
Mingo & Co.

Specializing in Basel II/III implementation and Economic Capital for major financial institutions. Areas of expertise include credit risk in securitization transactions and Pillar 2 stress testing techniques. Formerly Senior Advisor to the RMA Capital Working Group.

April 2006 to June 2009

Managing Director and Senior Advisor
Promontory Financial Group

Specializing in credit risk measurement issues and securitization issues.

June 1999 to April 2006

Managing Director
Mingo & Co.

Mission: providing advice to major financial institutions regarding the regulation and supervision of risk measurement and management (including evolving capital regulation).

January 1992 to June 1999

Senior Adviser, Division of Research and Statistics, Board of Governors, Federal Reserve System, Washington, DC

Areas of Responsibility:
o Bank Capital Regulations, including part of the team that secured the demise of the old Basel Accord
o Financial Market Structure
o Troubled Bank Strategies
o Co-Chairman, System Task Force on Internal Credit Risk Models
o Member, Interagency Securitization Working Group

January 1991 to January 1992

Managing Director and Founding Principal, The Potomac Financial Group, Inc.
Washington, DC

Areas of Specialization:
o Assisted Transactions
o Restructurings and Downsizings
o Strategic and Regulatory Planning

January 1981 to January 1991

Managing Director, BEI Golembe, Inc., Washington, DC

Areas of Expertise:
o Mergers & Acquisitions: financial analysis and negotiations
o Strategic Planning
o Regulatory Strategy
o Restructuring Alternatives
o Antitrust analysis for M&A transactions

Typical assignments: managed over twenty M&A transactions, including the largest branch divestiture in history ($6 billion in deposits); completed strategic planning assignments for banks in all size ranges; prepared legislative analyses for trade associations; prepared regulatory filings, including antitrust analyses, for merger parties.
August 1979 to January 1981

Department of the Treasury, Deputy Assistant Secretary for Financial Institutions
and Capital Markets Policy (on loan from Federal Reserve)

Areas of Responsibility:
o Interagency Task Force Study on the McFadden Act
o H.R. 4986, the Depository Institutions Deregulation and Monetary Control Act of 1980
o Issues before the Commodity Futures Trading Commission
o Report of the Interagency Task Force on Housing and Housing Finance (November 1979)
o The Depository Institutions Deregulation Committee
o Issues before the Pension Benefit Guaranty Corporation
o Report of the Interagency Task Force on Thrift Institutions, submitted to the Congress, June 1980

June 1972 - August 1979

Board of Governors, Federal Reserve System, Division of Research and Statistics. Senior Research Division Officer (1977-1979); Associate Adviser (1975-1976); Chief, Financial Studies (1973-1975); Economist, Banking Markets (1972-1973)

Areas of Responsibility:
o Bank capital standards
o Banks' use of interest rate futures
o Congressional testimony on banking legislation

July 1976 - September 1977

Abt Associates (Cambridge, Massachusetts); Senior Research Associate, National Science Foundation Grant

o During a 15-month leave of absence from the Federal Reserve, co-managed a team of eight academics in preparing a two-volume study on the "Benefits and Costs of Regulation of Consumer Financial Services."

September 1969 - June 1972
University of Montana, Assistant Professor of Economics and Director, Center for Economic Education



Married, two children



RMA Capital Working Group Papers (co-authored):
o "Response to BCBS 164 (revised Basel II capital requirements)", April, 2010
o "Response to BCBS 150 (securitization capital requirements)", April, 2009
o "Response to the Notice of Proposed Rulemaking for Basel II," March, 2007.
o "Future Margin Income and the EL Charge for Credit Cards for Basel II," RMA Journal, September, 2006.
o January, 2006, "Response to the Advanced Notice of Proposed Rulemaking on Basel II," January, 2006.
o September 2005, "Analysis of QIS4 Results - Level and Diversity."
o August 2005, "Downturn LGDs for Basel II."
o January 2005, "Response to the Proposed U.S. Supervisory Guidance for Retail Credit Risk Capital under the Basel II Framework."
o March 2004, "Industry Practices in Estimating EAD and LGD for Revolving Consumer Credits - Cards and Home Equity Lines of Credit."
o March 2004, "Capital Treatment of Credit Cards and Securitized Card Receivables."
o December 2003, "Response to the October 11, 2003 Basel Treatment of EL and UL."
o November 2003, "RMA Response to the ANPR and Supervisory Guidance Document."
o July 2003, "Response to Basel's Third Consultative Paper On the New Capital Accord."
o March 2003, "Measuring Credit Risk and Economic Capital in Specialized Lending Activities - Best Practices."
o February 2003, "Retail Credit Economic Capital Estimation - Best Practices."
o May 2002, "Response to Basel's Proposals for Allocating Capital to Securitizations."
o November 2001, "RMA Response to the Basel Working Paper on the IRB Treatment of Expected Losses and Future Margin Income."
o May 2001, "RMA Response to Basel II."
o December 2000, "Supervisory Accreditation Procedures for a Risk-Characteristic-Based Regulatory Capital Framework."
o December 2000, "Credit Risk Capital for Retail Credit Products: A Survey of Sound Practices."

Academic journal and other articles:

"Intrinsic Risk Measurement: A Model That Works," (with A. Dev and J. Buckler), RMA Journal, June 2009, pp. 36-40

"EDF Estimation: A Test-Desk Exercise (The RMA Capital Working Group)", Journal of Lending and Credit Risk Management, November 2000, pp. 54-61.

"Internal Credit Risk Rating System Must Evolve to Stay Relevant" (with E. Falkenstein), Journal of Lending and Credit Risk Management, May 2000, pp. 22-25.

"Policy Implications of the Federal Reserve Study of Credit Risk Models at Major U.S. Banking Institutions," Journal of Banking and Finance, 24, pp. 15-33, 2000.

"Industry Practices in Credit Risk Modeling and Internal Capital Allocations: Implications for a Models-Based Regulatory Capital Standard" (with D. Jones), Journal of Economics and Business, vol. 51, pp. 79-108, 1999.

"Toward an 'Internal Models' Capital Standard for Large Multinational Banking Companies," Journal of Lending and Credit Risk Management, June/July, 1998.

"Premiums in Private versus Public Bank Branch Sales" (with J. Berkovec and X. Zhang), Finance and Economics Discussion Series, Federal Reserve Board, no. 33, 1997.

"The Efficiency of Bank Branches" (with A. Berger and J. Leusner), Journal of Monetary Economics, vol. 40, no. 1, August, 1997.

"Bank Capital Requirements for Securitized Loan Pools" (with P. McAllister), Journal of Banking and Finance, December, 1996.

"Open-bank Assistance Transactions and Prompt Corrective Action," Journal of Financial Services Research, Volume 8, December, 1994, pp. 313-325.

"Commercial Loan Risk Management, Credit-Scoring, and Pricing" (with P. McAllister), Journal of Commercial Lending, May, 1994, pp. 6-22.

"RTC Rigidity Clobbers Taxpayers," American Banker, November 20, 1991, pp. 4-13.

"Open-Bank Assistance Can Work for All Stakeholders," American Banker, September 9, 1991, pp. 5-10.

"An Option for Raising New Capital: Selling The Crown Jewels," Banking Policy Report, Volume 10, Number 7, April 1, 1991, pp. 1-15.

"The Tantalizing Prospect of A Thrift Acquisition," American Banker, January 24, 1990, pp. 4-5.

"'Narrow Banks' Part of Plan for Restructuring Regulatory System" American Banker, September 15, 1987, pp. 5-13.

"A Critical Analysis of Capital Requirements," Thrift Financial Performance and Capital Adequacy, Proceedings of the Twelfth Annual Conference of the Federal Home Loan Bank of San Francisco, December 11-12, 1986, pp. 19-23.

"What Regulators Need is a Federal Policy on Bank Failures," American Banker Conference on Bank Capital, reprinted in American Banker, December 3, 1985, pp. 8-39.

"Can Supervision and Regulation Ensure Financial Stability," (with C. Golembe), The Search For Financial Stability: The Past Fifty Years, A Conference Sponsored by the Federal Reserve Bank of San Francisco, June 23-25, 1985, pp. 125-146.

"Bringing Thrift Capital Up To Standards," Banking Expansion Reporter, Volume 4, No. 10, May 20, 1985, pp. 1-15.

"Capital Ratios: The Reg Q Fiasco of the Future?" Banking Expansion Reporter, Volume 4, Number 2, January 21, 1985, pp. 1-14.

"Mutiny on the Bounty: The Omaha/Lincoln Decision," Banking Expansion Reporter, Volume 3, Number 11, June 4, 1984, pp. 1-15.

"Branch Divestitures: Valuation and Sales Strategies," Banking Expansion Reporter, Volume 1, Number 2, January 16, 1984, pp. 1-14 (with W. Spinard).

"Short-Run Structural Solutions to the Problems of Thrift Institutions," The Future of the Thrift Industry, Federal Reserve Bank of Boston, October 1981, pp. 81-106.

"The Economics of the Deposit Rate Differential and the Impact of a Mandated Differential," a research paper prepared for the National Conference on Competition In Banking, May 1, 1981.

"The Impact of Removal of Deposit Rate Ceilings on Bank Thrift Viability and on Housing Finance," The Deregulation of Depository Institutions, Proceedings of the Berkeley Business School Colloquium in cooperation with the Office of the Comptroller of the Currency, March 19, 1981, pp. 1-16.

Geographic Restrictions on Commercial Banking in the United States, The Report of the President, January 1981, co-authored (Department of the Treasury).

"A Note on the Microeconomics of Deposit Rate Ceilings: Inferences for NOW Accounts and Interest on Checking Accounts," Journal of Banking and Finance, December 1980, pp. 387-395.

Report of the Interagency Task Force on Thrift Institutions
, June 30, 1980, co-authored (Department of the Treasury).

Treasury Futures Markets, A Study by the Staffs of the U.S. Treasury and Federal Reserve System, May 1979 (co-authored).

"The Effect of Deposit Rate Ceilings on Bank Risk," Journal of Banking and Finance, December 1978, pp. 367-378.

"The Relationship Between Bank Soundness and Bank Size," (with B. Wolkowitz), Journal of Economics and Business, Winter 1978, pp. 119-123.

"On the Usefulness of Functional Cost Analysis Data," (with A. Heggestad), Journal of Bank Research, Winter 1978, pp. 251-256.

"External Capital Financing Requirements of Commercial Banks, 1977-1981," (with G. Hanweck), Staff Economic Studies, Number 95, Federal Reserve Board, December 1977. Reprinted in Issues in Bank Regulation, Volume 1, Number 4, Spring 1978.

"The Effects of Regulation on Bank Balance Sheet Decisions," (with B. Wolkowitz), Journal of Finance, December 1977, pp. 1605-1616.

Public Regulation of Financial Services, Cost and Benefits to Consumers, (with A. Heggestad), Report to the National Science Foundation, Abt Associates, Cambridge, Massachusetts, October 1977.

"Regulation of Financial Institutions: An Overview," Public Regulation of Financial Services, Cost and Benefits to Consumers, Report to the National Science Foundation, Abt Associates, Cambridge, Massachusetts, October 1977, pp. 129-168.

"The Economic Impact of Deposit Rate Ceilings," Ibid, pp. 245-275.

"The Competitive Condition of U.S. Banking Markets and the Impact of Structural Reform," (with A. Heggestad), Journal of Finance, June 1977, pp. 649-661.

"Managerial Motives, Market Structures, and the Performance of Holding Company Banks," Economic Inquiry, September 1976, pp. 411-448.

"Prices, Nonprices, and Concentration in Commercial Banking," (with A. Heggestad), Journal of Money, Credit and Banking, February 1976, pp. 107-117.

"Risk and Its Implications for the Banking System" Magazine of Bank Administration, (with S. Rhoades, B. Wolkowitz), two-part series, February 1976, pp. 53-58, March 1976, pp. 43-47.

"Capital Management by Holding Company Banks," (with A. Heggestad), Journal of Business, October 1975, pp. 500-505.

"Economic Dualism, Capital Imports, and the Demand for "Backward" Sector Products," Journal of Development Studies, October 1975, pp. 39-53.

"Regulatory Influence on Bank Capital Investment," Journal of Finance, September 1975, pp. 1111-1121.

"Capital Management and Profitability of Prospective Holding Company Banks," Journal of Financial and Quantitative Analysis, June 1975, pp. 191-203.

"The Regulation of Bank Holding Companies," (with S. Chase), Journal of Finance, May 1975, pp. 281-292.

"Capital Importation and Sectoral Development: A Model Applied to Postwar Puerto Rico," American Economic Review, June 1974, pp. 273-290.

"Prices, Nonprices, and Concentration in Selected Banking Markets," (with A. Heggestad), Bank Structure and Competition, Federal Reserve Bank of Chicago, March 1974, pp. 69-95.

"The Effects of Regulation on Bank Portfolios, Capital, and Profitability," (with B. Wolkowitz), Ibid, pp. 47-58.