THIS IS A WORK IN PROGRESS.

It turns out that a July 1996 GAO Report provided an answer to this question, only NO ONE in the Mainstream Media WAS PAYING ANY ATTENTION. There was a short blurb in the Financial Digest section of the business pages of the Washington Post. It read:

This information comes from the 1996 GAO Report and other material I received from the FDIC in early April based upon a Freedom of Information Act (FOIA) request. I have summarized the information in my web page "The Cost of the Savings and Loan Crisis of 1985 to 1995 to the American Taxpayer." In essence, some 1101 S&Ls failed between 1985 and 1995 with resolution costs of $154.5 billion dollars. Of this, the Thrift Industry paid for about $28.1 billion out of its insurance fund, leaving the American taxpayer to pick up the balance of $126.4 billion.

Many people actually believe the Barrons' estimate of fraud in the Savings and loan crisis as amounting to only 5% to 25% of the total. That estimate is calculated on the $126.4 billion and amounts to $6.32 billion (5%) to as much as $31.6 billion (25%).

Given the major role of Wall Street in creating the conditions that made the Debacle possible (see below), I am somewhat leary of accepting the Barrons estimate of the extent of the civil and criminal fraud and the amount of money defrauded by the American people.

In preparing my web page "Mr. Hyde and the Clyde S&L," I discovered a January 1997 letter from the Congressional Accountability Project to the Federal Deposit Insurance Corporation on the extent of Mr. Hyde's involvement in the collapse of the Clyde Federal Savings and Loan. The S&L, which collapsed on February 1st, 1990 had bailout costs to the American taxpayer of $67 million dollars, an amount almost as much as the $73 million dollar bailout of the much-investigated Madison Guaranty S&L in Arkansas. Although the board members of the S&L, including Mr. Hyde were sued by the FDIC, Mr. Hyde paid NOT ONE CENT towards the restitution of money to the American taxpayers.

By itself, this quotation from a GAO report invalidates the Barrons' figure that only from 5% to 25% of the nation's S&Ls involved criminal fraud. The fact that in Illinois there were 35 S&Ls where criminal activity was alleged, but only 6% of the 35 S&L criminal referrals resulted in a criminal prosecution makes me wonder if the Reagan and Bush-appointed Federal Attorneys in that state and several other states were reluctant to vigourously prosecute the criminal fraud activities of "well-connected" people.

The CAP got the information in the paragraph above from a 1993 General Accounting Office (GAO) Report. It is called "RTC Thrift Failures," General Accounting Office, August 10, 1993. GAO/GGD-93-94. I have obtained a copy of this report from the GAO and have analyzed the limited data within it. It is remarkable that so much money could be stolen with so little attention from the law enforcement and regulatory agencies of our government.

To begin with, the GAO report is limited to the 723 RTC Thrifts that failed between February 7, 1989 and August 28, 1992, and which were still under the RTC's control as of September 30, 1992. So the report does not include S&Ls such as the Mainland S&L in Texas, which failed on April 4,1986 with bailout costs of almost $916 MILLION dollars, but which was allowed to avoid any civil proceedings or criminal prosecution through the STATUTE OF LIMITATIONS ploy (see below).

According to the Federal Deposit Insurance Corporation (‘‘FDIC’’), over 1300 federally insured savings and loans failed in the United States between 1980 and 1995 with total assets of over $600 billion. (The Senate Whitewater Report 104-280, pp. 492-493). We now know that 1101 S&Ls failed between 1985 and 1995, with total assets of about $450 billion.

In the state of Arkansas during that same period, according to the Office of Thrift Supervision (‘‘OTS’’), the federal agency responsible for supervising federally insured savings and loans, 22 savings and loans failed with total assets of over $6.8 billion. The infamous Madison Guaranty, with assets of $114 million, was the eleventh largest failed Arkansas savings and loans.

Stated another way, 66% of the S&Ls on which CRIMINAL REFERRALS were filed somehow did not proceed to the status of a prosecuted CRIMINAL CASE. Thus, just 34% of the 503 S&Ls proceeded to an criminal investigation and a trial -- not remarkable in view of the fact that the Reagan, Bush, and the "Clinton" Departments of Justice were and are very reluctant to investigate and charge "well-connected" people. Of the S&Ls that failed before February 1989, my guess is that the percentage of CRIMINAL REFERRALS that resulted in CRIMINAL TRIALS was much smaller. The Mainland S&L in Texas is probably just one of the many S&Ls that went uninvestigated and uncharged.

Now CRIMINAL REFERRALS are only allegations of criminal activity, and may not proceed into a CRIMINAL INVESTIGATION and CRIMINAL TRIAL unless you have a dogged prosecutor like Kenneth Starr or very good criminal case that a prosecutor believes can be won. However, even a very good criminal case may not result in a CRIMINAL INVESTIGATION and TRIAL if the investigation leading to a CRIMINAL REFERRAL is delayed. As you will see below, this occurred in the case of the First Federal S&L in Arkansas which was not investigated for a period of two to three years. A delayed investigation was then initiated which resulted in CRIMINAL REFERRALS, but alas, the STATUTE OF LIMITATIONS had somehow run out.

In the table below, I have listed the top twenty states in which the INITIAL looting of the Savings and Loans were the most pronounced as evidenced by the number of failed S&Ls, (Appendix I of the GAO Report), the number of CRIMINAL REFERRALS TO S&Ls and the ESTIMATED DOLLAR LOSS OF ALLEGED FRAUD (Appendix III of the GAO Report), and the number of CRIMINAL CASES IN THE PROCESS OF BEING PROSECUTED (Appendix IV of the GAO Report). The

If this table shows anything, it shows the failure of the Reagan and Bush administrations to vigorously prosecute the criminals who defrauded the American taxpayer of billions of dollars in the INITIAL looting of the S&Ls. We get an another idea of the extent of the INTIAL looting of the S&Ls in the various states by looking at pages 119-120 of the 1991 World Almanac. Notice I keep repeating the INITIAL looting of the S&Ls. Although the information is extremely hard to find, basically because Wall Street and the Mainstream Media had made major attempts to conceal it -- the truth of the matter is that there was not ONE, but a SERIES OF FOUR LOOTINGS in the S&L Debacle.

 As we will discuss in more detail below, the third of the four lootings of the S&L took place when the RTC sold off properties for five or ten per cent of their value to "well-connected" people. In June 1990, the Resolution Trust Corporation released a list of 35,908 properties with a book value of $14.9 billion dollars that had been owned by 148 failed S&Ls. Of the properties, 18,346 were in (1) Texas, 2,890 in (2) Louisiana, and almost 2,000 each in the states of (3) Arizona (1,931), (4) Oklahoma (1,926), and (5) Colorado (1,838), and 1,456 in (6) the state of Florida. The state with the seventh largest amount of recovered S&L properties was New Mexico with 803 properties. In eighth, ninth, and tenth places were Georgia (659), Utah (487) and Kansas (477). Alabama, with 427 properties was eleventh and Illinois, with 367 properties, was twelfth. Notice that Florida was number six in the list of states, suggesting that the percentage of S&L failures caused by criminal fraud was probable much higher than the average of 24% for the states with the highest incidence of RTC disposed properties.

Let me make the case for FOUR LOOTINGS by briefly reviewing some recent history.

1. Ronald Reagan was the president of the United States from January 21, 1981 to January 21, 1989. The Republican party controlled the Senate of the U.S. Congress from January 21, 1981 to January 1987. The Republicans had a strong majority in the House of Representatives during this same period of time, with many votes being carried by a coalition of moderate and conservative Democrats and the Republican minority.

2. Much of the deregulation legislation was written by M.Danny Wall, a Senate staffer in the office of the senior Republican senator from Utah -- Jake Garn. In fact, the deregulatory law was the Garn-St.Germain Act (Fernand St. Germain was a Democratic representative from Rhode Island, who was booted out of office a short time later in the Democratic primary).

3. After Reagan signed the Garn-St. Germain Act, which among other things, raised the maximum insurance on an S&L deposit to $100,000, Wall Street firms immediately began to put together packages of $100,000 dollars each so their investors could invest in S&Ls spread across the country.

Here we see Wall Street pouring "hot money" accounts into S&Ls promising high returns on risky loans and investments. The investors were safe, their money packages were insured up to the maximum amount of money they invested in the individual S&Ls. According to the 1996 GAO Report, $221 billion dollars of the $277 billion dollars in liabilities at the S&Ls at the time they were "resolved" was in the liabilities to the depositors, whose $100,000 dollar "hot money" accounts were fully insured.

Wall Street was safe, it was receiving large commissions on the investments.

Who wasn't safe? Well it was the good old American taxpayer. We were the one that assumed the liability to pay off the insured investors when, as should have been expected, many savings and loans collapsed from 1983 onward.

Spurred by the deregulatory fervor of the President and his advisors, the regulatory agencies were stripped of regulators and investigators, and attempts by the remaining investigators to shut down S&Ls were stymied by "political operatives" in these agencies. One of these agencies was the Federal Home Loan Bank Board, which had regional offices across the country. The board of directors for each of the regional offices was selected by the senior S&L executives in each regional from their fellow executives.

In March 1987, two regulators from the Topeka Kansas FHLBB office attempted to close down Silverado Savings and Loan and were stopped by the head of the Topeka office. The move to close Silverado actually began in late 1986 when Dorothy van Cleave, an examiner at the Kansas Home Loan Bank and Terry Sandefur, an analyst at the same bank, were assigned to look at Silverado's books. Up until that time, Silverado was being touted as a "model prosperity" by the savings and loan industry and the deregulators in the Reagan Administration. Once van Cleave and Sanefur began to examine Silverado's books, the carefully-contrived Silverado "model of prosperity" began to unravel. But, as Steven Wilmsen writes, there was something even more disturbing about their findings, something

Steven R. Wise was the president of Silverado, Bill Walters was the largest developer in Denver, Kenneth M. Good the second-largest developer, while Larry Mizel was the fifth largest home builder in the United States. As I wrote in my letter, the collusion between these four men during the glory days of Silverado had to be seen to be believed. Wilmsen describes some of their initial dealings:

 The $3.2 million dollar profit Good and his partners realized from the "land flip" described above subsequently came out of the pockets of the American tax payer. It was clearly illegal, not only under federal law (remember the money invested in Silverado was federally-insured), but also under state and local laws. Yet Mr. Good was never investigated and never held to account for his role in creating the Silverado S&L losses. Perhaps it was because he had hosted a luncheon for Ronald Reagan in 1986 where $1,000,000 was raised for the Republican senatorial campaign fund.

Why had there been no investigation of Silverado or of Charles Keating's Lincoln Savings and Loan? On July 1, 1987, the Reagan-Bush White House, Senator Jake Garn, and U.S. League of Savings Institutions made M. Danny Wall the new Chairman of the Federal Home Loan Bank Board (FHLBB). Now that the odious Ed Gray was gone they had a "team player" who would contain a growing political problem until after the presidential elections of 1988. As the head of the U.S. League of Savings Institutions was quoted at the time as saying, Wall could not take a piss without his permission. After his appointment, Wall engaged in an unprecedented, and possibly illegal regulatory action for the former Republican national committeeman from Arizona, Charles Keating. This is best described on pp. 238 and 239 of Overdrawn: The Bailout of American Savings by Michael A. Robinson:

So in the original looting of the S&Ls from 1983 to 1988, a number of people made a great deal of money and the S&L regulatory agencies, the FBI, and the Justice Department looked the other way. Because the Mainstream Media has ignored the original looting, we do not know how extensive or how expensive it was for the American taxpayer. Among other things, up until I prepared it in April 1999, there wasn't even a list of the failed S&Ls showing the amount of money the American taxpayer had to provide for bail out costs in each case. The information of Silverado I provided on my web pages comes from just three books and is grossly incomplete.

However, this information does show that the regulators were only able to recover about 68% of the losses from Walters, which means almost a third of the money he obtained from Silverado -- $45 million dollars -- came out of the taxpayer's pocket. Because of this, it is fair to speculate that the amount of fraud in the original looting was probably about equal to the high figure of 25% in the Barrons reporting. And 25% of $155 billion dollars is about 38 to 40 billion dollars. But the amount of fraud in the first looting is still unknown. Thus, another question for the investigative reporter to answer:

After the S&L regulatory agencies took over the assets and the liabilities of the failed S&Ls, their first job was to calculate the amount of the liabilities of each S&L. Much of this was in those brokered $100,000 "hot money" packages that Wall Street had begun to peddle in late 1982 and early 1983. It didn't make any difference how the S&L lost the money-- through economics, through incompetence, or through criminal fraud, the S&L had pay back those Wall Street investors with the entire amount of their $100,000 dollar brokered certificates of deposit.

The second job of the S&L regulatory agencies was to examine the loan portfolio of each S&L and to identify the loan defaulters and attempt to recover the face value of the loan or a considerable percentage of it. The third job was to go over the property assets of each S&L, determine their true worth, and then to dispose of the property at the highest price. The fourth job was to carefully go over all of the financial papers of each S&L and look for instances where individuals or organizations could be sued in the civil court for civil fraud in an effort to recover some of money. The S&L regulatory agencies were also to look for criminal fraud or clear indications of criminal fraud in the various transactions of the failed S&Ls. While this provided several avenues by which money could be recovered, it actually provided three additional means by which certain "well-connected" individuals could profit at the cost of the American taxpayer.

According to the 1996 GAO Report, the "RTC closed 747 institutions with $402 billion in book value of assets when they entered the conservatorship phase." Then, the report tells us, the book value of $402 billion was reduced to $240 billion "through sales, collections, and other adjustments." Finally, in the receivership phase, the assets were reduced from $240 billion to $8 billion. Somehow, $394 billion dollars in assets -- loan portfolios and property -- disappeared. How did this happen?

The second article appeared on page A24 of the Washington Post on October 13, 1990. The article was by Sharon LaFraniere and its complete text can be retrieved from the Washington Post archive. The information below was culled from the Washington Post article:

In 1985, Jeb Bush and his partner Armando Codina borrowed $4.565 million dollars from the Broward Savings and Loan. The loan was brokered through a thrift owned by a Bush associate, J. Edward Houston. Bush and Codina then took $2 million dollars of this borrowed money to purchase a $9 million dollar Miami office building, arranging a $7 million dollar mortgage to cover the rest of the purchase price. They then took out a mortgage on the money they had borrowed from Broward through Houston. The remaining money from the loan, now $2.565 million dollars, was used for payments on the $7 million dollar mortgage, plus interest charges and other costs.

In 1990, an agreement with Bush and his partner was reached whereby the government forgave the $4.565 million dollar loan for a payment of $505,000. Bush and Codina walked away with $4.060 million dollars which included the $2 million dollar down payment on the $9 million dollar office, plus $2.060 million dollars for payments on $7 million dollar mortgage plus interest costs and a cash "kitty" of an unknown amount. In short, the American taxpayer was stiffed for $4.060 million dollars through a deal cut by federal employees of the Bush Administration and Bush's son and his partner.

Considering that the American taxpayer has paid out or will pay out over $411.6 billion dollars on the S&L debacle, $4.060 million dollars is just a drop in the bucket. But this story opens up a number of leads for an investigative reporter.

One of the hidden stories of Whitewater and the Madison Guaranty Savings and Loan is how "well-connected" individuals were able to make large profits from loans made to savings and loans which later collapsed. In the early 1980s, James McDougal, the lawyer Sheffield Nelson, and Jerry Jones, owner of the Dallas Cowboys, invested in a real estate development on Campobello Island, the former summer home of Franklin D. Roosevelt. The money spent by McDougal on the Campobello development in the early 1980's was one of the primary reasons Madison Guaranty failed a few years later at a cost of $73 million dollars in bailout costs. It now turns out that David Hale was also involved in this particular activity.

In 1988, someone in one of the Reagan S&L regulatory agencies was able to find enough money in the bleeding carcass of Madison Guaranty to completely return the Nelson and Jones investments and to provide each of them with an ADDITIONAL 65% return on their four-year investment. Questions for an an investigative reporter:

In June 1990, the Resolution Trust Corporation released a list of 35,908 properties with a book value of $14.9 billion dollars that had been owned by 148 failed S&Ls. Over 18,000 of the properties were in Texas, almost 3,000 in Louisiana, and almost 2,000 each in the states of Arizona, Colorado, and Oklahoma, and over 1,000 in the state of Florida. (Source: The 1991 World Almanac, pp. 11-120).

From this, we can get an INDIRECT indication of the states in which the bulk of the Savings and Loan Debacle took place.

01. Texas -- 18,346 properties - (3,063 commercial, 127 land, 15,156 residential)

02. Lousiana -- 2,890 properties total.

03. Arizona -- 1,931

04. Colorado -- 1,838

05. Oklahoma -- 1,926

06. Florida --1,456

07. New Mexico--803

08. Georgia--659

09. Utah--487

10. Kansas-477

11. Alabama -- 427

12. Illinois--367

13. Arkansas--365

14. Tennessee-353

15. Alaska--352

16. Mississippi--340

17. California--307

As far as I can tell, the owners and managers of the Mainline Media have been able to completely cover up the property disposal looting by the S&L regulatory agencies and certain "well-connected" persons and groups. The PBS program series Frontline had a single program on this about two to four years ago. In it, they interviewed several non-profit public-service groups that were trying to obtain the S&L properties at low cost. Somehow or another, the S&L agencies sold the properties to certain individuals and certain groups, many of whom had been involved in the INITIAL looting of the S&Ls. The Clinton Administration evidently put out directives saying that non-profit public-service groups should be given first priority in acquiring the S&L properties, but the S&L agencies were able to ignore this and continue to sell at cut-rate prices to "well-connected" persons and groups. Clinton and the Clinton administration were too busy answering questions about Whitewater or some other scandal of the week. Questions for an investigative reporter:

Evidently the owners of the Mainstream Media thought this was information the American people did not need during President Bush's first year in office. As far as I can determine from the archives of the Miami Herald, a Knight-Ridder newspaper, the Berkovitz testimony was never reported in that newspaper. The Bush-appointed Federal attorney made no effort to determine if Berkovitz was telling the truth or if he was perjuring himself. If he was telling the truth, then vice President Bush had violated the powers of his office and should have been impeached for obstruction of justice. There was no public outcry about this testimony because it appears it was never reported by the Mainstream Media. The story was reported in an obscure Miami legal newspaper, the Miami Review on May 22, 1989, and was dug out by Pete Brewton and published in his book The Mafia, the CIA, and George Bush, on pages 324-325.

As reported in ALL OF TWO NEWS ARTICLES in the Washington Post in August 1992, the FSLIC and the FHLBB and their successor agency, the Reconstruction Trust Corporation (RTC), had been accused of rampant political favoritism during the Bush Administration.

(The Deseret Federal Savings and Loan failed on February 10, 1989, with bailout costs of $83 million dollars.)

A possible criminal obstruction of justice in the case of the failed Mainland Savings and Loan in Texas occurred during the Reagan and Bush administrations. Mainland is another S&L identified in the 1985 Controller of the Currency's report as being controlled by Herman Beebe and his associates or having significant dealings with them. Beebe had had significant links to the CIA, to the Mafia and to other organized crime groups in this country before and during much of the time of the S&L debacle.

Raymond Hill, of an old-line Republican family in Houston and William D. Shepherd purchased a small Texas City, Texas savings and loan, Mainland Savings in the early 1960's. Mr. Shepherd was later convicted of stealing $1.3 million dollars from several financial institutions in exchange for worthless checks drawn on the Bank of Sark in the British Channel Islands.

Mr. Hill moved Mainland to Houston, Texas in 1975 and was the CEO of Mainland until it collapsed on April 4, 1986. With "illusory assets" of $1 billion dollars, it was the biggest S&L failure in the country at that time. The bailout costs for Mainland were almost a billion dollars -- $915,798,000 dollars.

During their investigations into the causes of the Mainland failure, two Houston Post reporters received an anonymous tip indicating that Mainland had been swindled of $141 million shortly before it failed. The two reporters later traced the scam to a group of New York investors with Mafia associations. They then discovered that Mainland had been one of 18 "friendly" savings and loans nationwide into which Mario Renda and Martin Schwimmer, associates of the Gambino Family of New York, had brokered union pension funds and then skimmed the interest off into secret accounts. Renda was also closely associated with Adnan Kashoggi of later Iran-Contra fame.

Further investigations by the Post reporters, and in particular Pete Brewton, led to the discovery of Mainland ties to the CIA, to Iran-Contra and to other failed S&Ls in the Southwest that also had ties to the Mafia and to CIA operatives.

When Brewton took the file to FSLIC he was told the officers and directors of Mainland (including Hill) did not have enough assets to justify the cost of a lawsuit. When Brewton took the unfiled lawsuit to the Reagan-appointed Federal Attorney in Houston, he was asked where he had acquired the document. The Federal Attorney was later forced out of his job by strong congressional criticism having to do with his not cracking down on S&L fraud and his past connections with several S&L's. Brewton doesn't know if the lawsuit was never filed because of the CIA connection or because of the influence on senior members of the law firm. It turns out that the Reagan Treasury Secretary James A. Baker III had been the former managing partner of Andrews and Kurth and a close personal friend of Raymond Hill since childhood.

In comparison with the states of Texas, Lousiana, Arizona, Colorado, Oklahoma and Florida, the state of Arkansas is small peanuts in the looting of American savings and loans. However, because of Whitewater, we have a possible window into a major obstruction of justice involving "well-connected" individuals and S&Ls, and the Resolution Trust Corporation.

As I mentioned above, each of the Regional S&L regulatory offices had an investigative section charged with the examination of the paper trail from failed S&Ls in an effort to uncover civil fraud and criminal fraud and to provide referrals to the Justice Department for these so that appropriate civil or criminal action could take place. The Minority Report of the Democrats picks up the story from this point:

I again need to interject at this point that the Gerth article had been researched out of the law offices of Sheffield Nelson, the Republican National Committeeman for the State of Arkansas.

The Tulsa field office of the RTC, where Lewis was assigned at the time, received inquiries about the Gerth article from two senior RTC officials shortly after the article's publication. Lewis' supervisor, Richard Iorio, testified that the scope of both inquiries was strictly limited to the simple question whether there was "any truth" to Gerth's allegations; neither inquiry sought a significant investigation of Madison Guaranty or suggested that Lewis should advance the investigation of Madison Guaranty from its place near the bottom of her agreed upon 1992 list.

In their Minority Report on Whitewater, the Democratic Senators were attempting to discredit the actions of L. Jean Lewis, a principal player in the Whitewater Scandal. However, if the records of the investigative section led by Lewis for the years 1992 through 1994 are examined for the top twelve failed S&Ls in Arkansas, something much more significant is shown:

Evidently the investigation started out examining the top six failed S&Ls (and four of the small fry) in Arkansas in the beginning of 1992, and the clock STARTED TICKING on the three-year STATUTE OF LIMITATIONS. Thereafter ALMOST ALL of the investigative effort was directed at Madison Guaranty and First Savings of Paragould. In 1993, the first year of the Clinton presidency, the top targets were again Madison Guaranty and First Savings of Paragould with Savers Savings being investigated for 105 hours. In 1994, the second year of the Clinton administration, Madison Guaranty consumed the bulk of the investigative time, with one the "small fry," the Arkansas Federal Savings Bank (loss: $16 million), being investigated for 249 hours.

Excluding Madison Guaranty, we should note that in 1994, the other top eleven failed S&Ls in Arkansas were only examined for a total of 14 hours. From this it is possible to infer that the hours spent in the Madison Guaranty investigation "saved" the other failed S&Ls in Arkansas from investigation.

It is difficult to understand how an RTC investigative program initially established in December 1991 and correctly pointed at the largest failed S&Ls in Arkansas was turned around in early 1992 and pointed directly and exclusively at Madison Guaranty and a number of much smaller S&Ls.

By 1993, it was clear the investigative burden had been shifted and this became even more evident in 1994 when exactly no investigative hours were directed at the top four failed S&Ls in Arkansas, with bailout costs of $833 million, $645 million, $314 million, and $91 million, for a total of $1.883 billion dollars. Looking at the failed S&Ls below Madison Guaranty in 1994, we see seven additional failed S&Ls with little or no investigation, although their bailout costs totalled $286 million dollars.

Information on the investigative hours directed against the failed savings and loans in other states handled by the same regional office and by other regional offices should be available for examination.

Remember, Arkansas was the 13th on the list of states involved in the S&L Debacle of the Reagan, Bush, and Clinton administrations. If this was the record of investigations for Arkansas, what was it for Texas, Lousiana, Arizona, Colorado, Oklahoma, Florida, New Mexico, Georgia, Utah, Kansas, Alabama, and Illinois?

I note in the case of First Federal and Mainland that the statute of limitations had expired on the criminal allegations pertaining to both S&Ls. But if the statute of limitations HAD BEEN ALLOWED to expire BECAUSE OF AN OBSTRUCTION OF JUSTICE, then the statute of limitations has been voided. To properly prosecute such cases, the Justice Department needs to establish if there was criminal collusion between federal employees in the S&L regulatory agencies and the "well-connected" people who were protected from investigation and criminal charges. Unfortunately the FBI and the Justice Department itself may have been involved in the same criminal conspiracy that protected the "well-connected" from investigation and prosecution.

For this reason I believe an Office of the Independent Counsel (OIC) for the investigation of the looting of the Savings and Loans during the Reagan, Bush, and Clinton administrations needs to be established.

In addition, the American people need to be informed of the number of savings and loans involved in the S&L debacle and lists need to be prepared as follows: