Promontory Financial Group

The company was founded in 2001 by Eugene Ludwig, who served as Comptroller of the Currency under President Bill Clinton, and Alfred H. Moses, a partner in the law firm Covington & Burling LLP. Promontory is based in Washington, D.C. and has 18 additional offices and affiliates worldwide, in Atlanta, Beijing, Brussels, Denver, Dubai, Dublin, Hong Kong, Istanbul, London, Madrid, Milan, New York City, Paris, San Francisco, Singapore, Sydney, Tokyo, and Toronto.

IBM announced its planned acquisition of Promontory in September 2016"Promontory Group Signs Up with IBM," Wall Street Journal, September 29, 2016 and completed the transaction in November 2016."IBM Closes Acquisition of Promontory Financial Group," IBM Press Release, November 22, 2016 Ludwig retired as CEO on February 28, 2021, passing the reins to an operating committee co-chaired by Julie L. Williams, Promontory's global head of strategy, and Leslie Peeler, chief operating officer.{{Cite web |date=2021-02-17 |title=Eugene Ludwig to step down as Promontory CEO |url=https://www.americanbanker.com/news/eugene-ludwig-to-step-down-as-promontory-ceo |access-date=2023-01-31 |website=American Banker |language=en}}

Promontory Financial is affiliated with several similarly named companies:{{cite web | url =http://www.promontory.com/Firm/Affiliated_Companies/ | title =Affiliated Companies | publisher = Promontory Financial Group | accessdate =18 July 2013 }}

• Promontory Forensics Solutions, LLC
• Promontory Growth and Innovation
• Promontory Human Capital Solutions
• Promontory Risk Review, LLC

Approximately 170 of the consultants working for Promontory were former employees of authorities in financial supervision. The news media has sometimes referred to Promontory as a "shadow regulator" for Wall Street. The American Banker newspaper described Promontory under Ludwig's leadership as "a go-to for banks seeking insight on regulatory matters from a stable of former officials from the Office of the Comptroller of the Currency, Federal Deposit Insurance Corp., Federal Reserve, Securities and Exchange Commission and other agencies."“Eugene Ludwig to step down as Promontory CEO,” American Banker, February 17, 2021

Former government officials currently associated with Promontory include:

• Sarah Bloom Raskin. Former United States Deputy Secretary of the Treasury, former member of the Federal Reserve Governor, and former Maryland Commissioner of Financial Regulation. Served as managing director of Promontory Financial Group, Washington. Currently a Promontory Advisory Board vice chair.{{Cite web|url=https://www.treasury.gov/press-center/press-releases/Pages/jl2321.aspx|title = Sarah Bloom Raskin Confirmed as Deputy Secretary of the Treasury}}
• Mary Schapiro. Former chair of the Securities and Exchange Commission and former chair of the Commodity Futures Trading Commission. Joined Promontory in April 2013 as managing director and chair of its governance and markets practice. Currently a Promontory Advisory Board vice chair.{{cite web|url=http://www.businessinsider.com/mary-schapiro-joins-promontory-2013-4 |title=Former SEC Chief Mary Schapiro Is Joining 'Shadow Regulator' Promontory Financial Group|author= Julia La Roche|publisher=Business Insider |date=April 2, 2013}}
• Julie L. Williams. Former first senior deputy comptroller and chief counsel and two-time former acting Comptroller of the Currency.{{Cite web |date=2013-01-09 |title=Julie Williams, OCC's Former No. 2, to Join Promontory |url=https://www.americanbanker.com/news/julie-williams-occs-former-no-2-to-join-promontory |access-date=2023-01-31 |website=American Banker |language=en}} Current co-chair of the firm's operating committee."Eugene Ludwig to step down as Promontory CEO," American Banker, February 17, 2021
• Dr Jeffrey Carmichael. Former founding chair of the Australian Prudential Regulation Authority following 20 years with the Reserve Bank of Australia. Dr. Carmichael is Chief Executive Officer of Promontory Financial Group Australasia (PFGA).

Former government officials previously associated with Promontory include:

• Elizabeth McCaul. Former New York Superintendent of Banks. Former head of New York office of Promontory, global head of strategy, and interim chair of Promontory Financial Group Europe."ECB hires ex-Goldman Sachs banker as watchdog," Reuters, July 11, 2019{{Cite web|url=https://www.bankingsupervision.europa.eu/press/pr/date/2019/html/ssm.pr190711~8b3c135a9e.en.html|title=New members of the Supervisory Board appointed|date=11 July 2019}}
• David Nason. Former Assistant Secretary for Financial Institutions, U.S. Treasury. Served as managing director of Promontory Financial Group, Washington.{{Cite news |last=Solomon |first=Deborah |title=Treasury Aide Nason Will Advise Companies |url=https://www.wsj.com/articles/SB123836576351067375 |access-date=2023-01-31 |newspaper=Wall Street Journal |date=30 March 2009 |language=en-US}}{{Cite web |title=Nason Named New President/CEO of GE Energy Financial |url=https://www.abfjournal.com/dailynews/nason-named-new-presidentceo-of-ge-energy-financial/ |access-date=2023-01-31 |website=ABFJournal |language=en-US}}
• Tommaso Padoa-Schioppa (1940-2010). Former Italian Minister of Economy and Finances and former chairman of the Basel Committee on Banking Supervision. Served as chairman of Promontory Financial Group Europe until his death.{{Cite web| title=Markets and Government Before, During, and After the 2007–20XX Crisis | url=http://www.perjacobsson.org/lectures/062710.pdf | archive-url=https://web.archive.org/web/20110727173129/http://www.perjacobsson.org/lectures/062710.pdf | archive-date=2011-07-27}}{{Cite news |date=2010-12-19 |title=Padoa-Schioppa, Founding Member of ECB Board, Dies |language=en |work=Bloomberg.com |url=https://www.bloomberg.com/news/articles/2010-12-18/padoa-schioppa-founding-member-of-ecb-board-dies-at-70 |access-date=2023-01-31}}

After uncovering foreign exchange losses in its U.S. banking subsidiary, Allfirst Financial Inc., Allied Irish Bank in 2002 engaged Promontory to conduct an internal investigation. Promontory issued the "Ludwig Report", on March 14, 2002. The report detailed how the trader John Rusnak hid losses of $691 million over five years."Bank Boards Discuss a Report on Losses by Currency Trader," Jonathan Fuerbringer, New York Times, March 13, 2002. The report concluded that Rusnak, who was fired for his role in the trading losses, received no active help from within or outside the bank. Promontory found that the internal control mechanisms and audits had been insufficient.{{cite web | url=http://www.aibgroup.com/servlet/BlobServer/document.pdf?blobkey=id&blobwhere=1015597173380&blobcol=urlfile&blobtable=AIB_Download&blobheader=application/pdf&blobheadername1=Content-Disposition&blobheadervalue1=document.pdf | archive-url=https://web.archive.org/web/20160304071009/http://www.aibgroup.com/servlet/BlobServer/document.pdf?blobkey=id&blobwhere=1015597173380&blobcol=urlfile&blobtable=AIB_Download&blobheader=application%2Fpdf&blobheadername1=Content-Disposition&blobheadervalue1=document.pdf | url-status=dead | archive-date=4 March 2016 | title=The Ludwig report: implications for corporate governance | trans-title=Report to the Boards of Allied Irish Banks, p.l.c., Allfirst Financial Inc. and Allfirst Bank Concerning Currency Trading Losses | author=Promontory Financial Group | publisher=MCB UP Ltd | date=12 March 2002 | accessdate=25 July 2013 }}

Promontory advised further the government of the United States and from other countries like Cameroon and Iceland.{{cite web | url=http://www.atvinnuvegaraduneyti.is/media/Acrobat/Report-on-Iceland-Supervision.pdf | title=Report on Iceland Supervision |trans-title=Prepared for the Icelandic Authorities, the FME and the IMF | author=Pierre-Yves Thoraval | publisher=Promontory Financial Group | series=Banking Supervision | date=15 April 2011 | accessdate=15 July 2013 | format=pdf; 9,2 MB}}

Promontory was hired to carry out by order of the Holy See a comprehensive investigation of all customer contacts of the Institute for the Works of Religion ({{langx|it|Istituto per le Opere di Religione}} – IOR), often also called the Vatican bank, on money laundering guided by former Promontory Europe executives Elizabeth McCaul and Raffaele Cosimo.{{cite web | url=http://www.businessweek.com/articles/2013-07-02/a-money-smuggling-scandal-threatens-to-sink-the-vatican-bank | archive-url=https://web.archive.org/web/20130704234443/http://www.businessweek.com/articles/2013-07-02/a-money-smuggling-scandal-threatens-to-sink-the-vatican-bank | url-status=dead | archive-date=July 4, 2013 | title=A Money-Smuggling Scandal Threatens to Sink the Vatican Bank |trans-title=Promontory Financial Group will conduct a forensic review and screen the Vatican Bank's client relationships—which some say might be "irreformable" | author=Carol Matlack | publisher= Businessweek | date=2 July 2013 | accessdate=27 July 2013}}{{cite web | url=http://www.osservatoreromano.va/portal/dt?JSPTabContainer.setSelected=JSPTabContainer%2FDetail&last=false=&path=/news/vaticano/2013/150q13-Comunicato-della-Sala-Stampa-della-Santa-Se.html&title=Resignations%20from%20the%20executive%20board | title=Resignations from the executive board | publisher=L'Osservatore Romano | date=3 July 2013 | accessdate=30 July 2013}}

In the aftermath of the subprime mortgage crisis, Promontory was one of several consulting firms selected by federal banking regulators to conduct reviews of loan foreclosures initiated by 16 mortgage servicing companies. Promontory reviewed the foreclosure activities of Bank of America, PNC Financial Services and Wells Fargo, encompassing more than 250,000 loan contracts. Promontory was paid $927 million, which led to strong criticism and doubt about the independence of the examination.{{cite web | url=https://dealbook.nytimes.com/2013/06/20/senator-criticizes-lack-of-supervision-for-banks-consultants/ | title=Senator Criticizes Lack of Supervision for Banks' Consultants - NYTimes.com | author= Protess, Ben |author2=Silver-Greenberg, Jessica | author3=Senator Brown, Sherrod | work=The New York Times | series=DealBook | date=20 June 2013 | accessdate=15 July 2013 | quote=New documents suggest that the Promontory Financial Group, which examined loans for Wells Fargo, Bank of America and PNC, was the highest paid of the consultants. The firm, run by a former comptroller of the currency, Eugene Ludwig, received $927 million for reviewing more than 250,000 loan files, according to documents provided to the Senate Banking Committee and reviewed by The Times.}} A hearing was arranged by the U.S. Senate Banking Committee to assess whether regulators had handed off too much oversight authority to private consulting firms such as Promontory.{{cite web | url=https://dealbook.nytimes.com/2013/04/09/for-former-regulators-a-home-on-wall-street/ | title=Promontory Financial Draws Washington Scrutiny - NYTimes.com |trans-title=Former Regulators Find a Home With a Powerful Firm | author= Protess, Ben |author2=Silver-Greenberg, Jessica | work=The New York Times | series=DealBook | date=9 April 2013 | accessdate=15 July 2013}}

Promontory was also engaged by Commonwealth Bank to oversee their Open Advice Review{{cite web|title=Commonwealth Bank names former regulator Jeff Carmichael to oversee financial advice review, 2014|url=https://www.smh.com.au/business/commonwealth-bank-names-former-regulator-jeff-carmichael-to-oversee-financial-advice-review-20140810-102ine.html|publisher=Sydney Morning Herald|date=2014-08-10}}{{cite web|title=Submission Senate Economics References Committee: Inquiry into the scrutiny of financial advice, 2014|url=https://www.commbank.com.au/content/dam/commbank/about-us/news/on-the-record/2014/scrutiny-of-financial-advice-inquiry-submission-05-12-2014.pdf|publisher=Commonwealth Bank of Australia|date=2014-12-05}} in 2014 and by Westpac to undertake an independent review into their breach of anti money laundering laws{{cite web|title=Westpac appoints CBA's auditor to fix risk management, 2019|url=https://www.afr.com/companies/financial-services/westpac-appoints-cba-s-auditor-20191128-p53f4a|publisher=Australian Financial Review|date=2019-11-28}} in 2019.

In August 2015, Promontory entered into an agreement with the New York Department of Financial Services to resolve the state's allegations that it had watered down compliance reports for a UK banking client, Standard Chartered Bank. Promontory agreed to pay a $15 million penalty and voluntarily abstained for six months from accepting new consulting engagements in New York.{{Cite news|url=https://www.wsj.com/articles/promontory-settles-with-ny-regulator-on-standard-chartered-investigation-1439923453|title = Promontory to Pay $15 Million in Settlement of Standard Chartered Case|newspaper = Wall Street Journal|date = 18 August 2015|last1 = Matthews|first1 = Christopher M.}}

{{Portal|Business and economics}}

{{-}}

{{IBM}}

Category:Financial services companies established in 2001

Category:Financial services companies of the United States

Category:Strategy consulting firms of the United States

Category:Information technology consulting firms of the United States

Category:International information technology consulting firms

Category:Consulting firms established in 2001

Category:Financial services companies based in Washington, D.C.

*

Category:IBM acquisitions

Category:IBM subsidiaries

Category:2016 mergers and acquisitions