[Congressional Record Volume 140, Number 35 (Thursday, March 24, 1994)]
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[Congressional Record: March 24, 1994]
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             H O U S E  O F  R E P R E S E N T A T I V E S


Vol. 140


WASHINGTON, THURSDAY, MARCH 24, 1994

No. 35--Part II


House of Representatives

   A POINT OF PERSONAL PRIVILEGE--ALLEGED BREAKDOWN OF COMITY AMONG 
COMMITTEE MEMBERS IN RELATION TO OVERSIGHT HEARINGS ON RESOLUTION TRUST 
                              CORPORATION

  Mr. LEACH. Madam Speaker, I rise to a point of personal privilege of 
the House.
  The SPEAKER pro tempore (Mrs. Kennelly). The gentleman from Iowa has 
risen to a point of personal privilege, and he has indicated to the 
Chair the press accounts which give rise to the request for the 
personal privilege.
  The gentleman from Iowa [Mr. Leach] is now recognized for 1 hour.
  Mr. LEACH. Madam Speaker, I rise to a point of personal privilege of 
the House.
  In rising to this point of privilege, I wish to express concern about 
the breakdown of comity that has occurred on a personal and procedural 
level in the House Banking Committee.
  On a personal level, unfortunate adjectives have been used; on a 
procedural level, unprecedented tactics have been employed.
  I don't wish to dwell on the personal, except to stress my high 
regard for the chairman of the Banking Committee and to suggest that, 
as the theologian Reinhold Niebuhr once observed, the temper and 
integrity of the political debate is more important in our kind of 
democracy than the outcome of any issue.
  Motivational aspersions are no substitute for full disclosure; 
indignation no substitute for pursuit of truth.
  Members of the majority may be speaking the truth when they indicate 
they have no evidence of a link between the failure of an Arkansas S&L 
and Whitewater and that they know of no improprieties at issue. But it 
should be understood that not speaking an untruth is not the same as 
describing a truthful situation, particularly if there has been no 
serious effort to pursue the truth.
  Constitutionally it is the duty of Congress to oversee breaches of 
law or public ethics in the executive branch. During the 12 years of 
the so-called divided Government of the Reagan/Bush era, the 
legislative branch took its constitutionally mandated oversight 
function seriously, as witnessed by the expansion in the size of its 
staff and the number of investigations undertaken.
  Now both the executive and the legislative branches of Government are 
controlled by the same political party. The oversight mandate thus 
falls disproportionately upon the ranking members of the respective 
committees for those areas of the executive branch over which they have 
jurisdiction. Not to assume leadership in performing the oversight 
function with regard to the way in which the financial institutions of 
this country are managed and regulated would be to violate my oath to 
``support and defend the Constitution of the United States * * * and * 
* * well and faithfully discharge the duties of the office.''
  If the majority party refuses to uphold its responsibilities because 
of political embarrassment to its party's top elected official, the 
minority party is left with the choice either of joining in a 
complicity of silence or pursuing investigations that run the danger of 
being partisan.
  In this context, I would simply emphasize that I raised the 
Whitewater issue with great reluctance, realizing the import as well as 
the power of the Presidency. I fully understand the political and 
personal liabilities involved. Nonetheless, I feel it would be 
inconsistent, indeed, hypocritical, to my own values, if I refused to 
pursue a line of inquiry potentially embarrassing to the President of a 
country which from its inception was intended to be hallmarked by law 
and its applicability to all citizens. It is, after all, the 
establishment of a government of laws, not men, that defines the 
uniqueness of the American experiment with democracy.
  Procedurally, it should be noted that the minority is currently 
engaged in one of the most profound checks and balances philosophical 
engagements with the executive branch in the modern history of the 
Congress. This engagement carries far greater implications than any 
judgment relating to a particular embarrassment of a particular public 
official at a particular time because at issue is precedent: whether in 
future circumstances the oversight capacities of Congress can be 
thwarted if the majority party of Congress is the same as that in 
control of the executive branch and chooses to refrain from its 
oversight obligations in order not to embarrass its party's standings.
  It is possible that the constitutional precedent for our checks and 
balances system surrounding the refusal of the administration to 
cooperate with an oversight probe of the executive branch which the 
majority party does not sanction may have more long-term negative 
consequences than any episodic embarrassment that might relate to this 
or any President's past. What is at issue is the definition of Congress 
as it applies to the constitutionally granted oversight 
responsibilities of the legislature. In our checks and balances system, 
Congress was given oversight responsibilities, but this administration 
is suggesting in response to minority requests for documentation from 
executive agencies that only chairmen speak for Congress. The minority 
in Congress, by this logic, has no power to advance or fulfill its 
constitutional rights if the majority does not concur in request for 
information. If such precedent is allowed to stand, Congress's 
oversight capacities will for all practical purposes be hamstrung 
whenever the executive and legislative branches of Government are 
controlled by the same party. Would our Founding Fathers have had this 
in mind?
  In this connection, on December 9, 1993, as ranking member of the 
Banking Committee, I wrote Federal regulatory agencies to request 
certain documents of an oversight interest [example, Tab A]. In a 
followup letter I pointed out, as the courts have noted, ``The Congress 
rarely acts as a body. Its manifold duties in the legislative, 
investigative, and oversight fields are almost invariably carried out 
through committees, committee chairmen, individual members, and staff 
personnel.'' Murphy v. Department of Army, 613 F.2d 1151, 1156 (1979). 
In addition, the court stated:

       The Senate and the House are so organized that certain 
     legislative and quasi-legislative activities may be 
     accomplished only through committee action. In other 
     respects, however, the legislature acts through its 
     individual Members. All Members have a constitutionally 
     recognized status entitling them to share in general 
     congressional powers and responsibilities, many of them 
     requiring access to executive information. It would be an 
     inappropriate intrusion into the legislative sphere for the 
     courts to decide without congressional direction that, for 
     example, only the chairman of a committee shall be regarded 
     as the official voice of the Congress for purposes of 
     receiving such information, as distinguished from its ranking 
     minority member, or other committee members, or other members 
     of Congress. Each of them participates in the law-making 
     process; each has a voice and a vote in that process; and 
     each is entitled to request such information from the 
     executive agencies as will enable him to carry out the 
     responsibilities of a legislator.

  Agency heads responded that a ranking member only has the authority 
of an individual Member of Congress and, therefore, may only obtain 
information that would be available to the public pursuant to the 
Freedom of Information Act. In addition, the Office of Thrift 
Supervision asserted that it differs ``with the view that Rules X and 
XI of the House of Representatives grant to a ranking minority member--
or any individual member--the same authority to request information 
that a committee chairman possesses.'' In short, the agencies contend 
that only chairmen, not ranking members, speak for Congress.
  Subsequently, on March 8, 1994, I wrote requesting information for 
the Banking Committee's upcoming RTC oversight hearing [Tab B]. Agency 
heads again responded by holding to the position that only the chairman 
of a committee would be permitted access to agency documents.
  In this dispute about who is entitled to speak for Congress in the 
context of Congress' right and obligation under Article I of the 
Constitution to conduct oversight of the executive branch, the chairman 
of the Banking Committee, in what may have been an effort to bolster 
the executive's position, wrote agency heads on March 10, 1994, to 
suggest that they deny my document request and wrote separately on 
March 14, 1994, to state that they need not answer questions concerning 
Madison Guaranty Savings and Loan at the scheduled hearings [Tabs C and 
D]. The chairman's letter contained an implicit and unprecedented 
philosophical assertion that not only does a chairman have the 
exclusive right to obtain oversight documents from the executive 
branch, but the right to deny such documentation to other Members and 
the right even to deny inquiries about issues clearly germane to the 
subject of hearings.
  So that there is no misunderstanding, the RTC oversight hearing was 
scheduled under requirement of law, section 21A(k)(6) of the Federal 
Home Loan Bank Act (12 U.S.C. Sec. 1441a(k)(6)), and there is no 
provision in that law for exceptions to congressional oversight that 
relate to a single State and its institutions. The U.S. Congress wrote 
a law applicable to all 50 States, not 49, and the oversight of our 
laws applies throughout this country. Just as in America no individual 
is above the law, no State is beyond its reach. Just as no individual 
is entitled to violate the law out of ignorance of it, no person, even 
the chairman of a congressional committee, is entitled after the fact 
to be sole interpreter of a law's meaning or serve as a censor to 
another Member's inquiries. Indeed, no Member of Congress has the right 
or power to deny relevant information to another Member.
  In addition to the Federal Home Loan Bank Act, the committee's role 
in oversight is buttressed by the House rules as modified under the 
Legislative Reorganization Act of 1970. I refer to paragraph 2 of House 
Rule X providing for the committee's ``General Oversight 
Responsibilities'' which states:

       (b)(1) Each standing committee . . . shall review and 
     study, on a continuing basis, the application, 
     administration, execution, and effectiveness of those laws, 
     or parts of laws, the subject matter of which is within the 
     jurisdiction of that committee and the organization and 
     operation of the Federal agencies and entities having 
     responsibilities in or for the administration and execution 
     thereof, in order to determine whether such laws and the 
     programs thereunder are being implemented and carried out in 
     accordance with the intent of the congress and whether such 
     programs should be continued, curtailed, or eliminated.

  Separate procedural rules may apply to an investigative hearing, but 
such rules do not apply in this case. The statutorily mandated RTC 
hearing is an oversight hearing in accordance with rule X. Any reliance 
on investigative hearing procedures to deny information to committee 
members is misplaced. Any information requests or questions by Members 
related in any manner to RTC operations are authorized under the 
committee's oversight authority. It is also expected that in answering 
questions witnesses have the obligation either to assert appropriate 
privileges or fully respond with answers to the questions (See, 2 
U.S.C. Sec. 192, Sinclair v. United States, 279 U.S. 263 (1929)) and 
such answers shall be truthful. (See, 18 U.S.C. Sec. 1001, U.S. v. 
Poindexter, 951 F.2d 369 (D.C. Cir. 1991)).

  Moreover, the precedent of the Banking Committee is clear with 
respect to the relevance of specific questions on specific 
institutions. On numerous occasions at past RTC oversight hearings, 
questions related to individual institutions have been asked by 
committee members, including the chairman, and answered by witnesses. 
In fact, the committee's invitation letter of March 3, 1994, to 
Treasury Secretary Bentsen for purposes of the RTC oversight hearing, 
seeks testimony and documents related to a specific institution, 
Homefed Savings. Of relevance also is the following statement last week 
of the chairman of the Senate Banking Committee:

       So we have had now over the years since 1989, a very long 
     series of regular oversight hearings where we call in the 
     officials responsible for implementing that law to find out 
     exactly how it is working and if there is a need to change 
     any particular part of it. Is it working the way it was 
     designed to work? Have we corrected all the abuses? We were 
     so concerned about that issue that, in fact, we built into 
     that 1989 law a requirement that there has to be a hearing 
     here in Congress every 6 months on how that cleanup effort is 
     doing and how that law is being implemented. Within the text 
     of that part of the law we went so far as to say that any 
     institutions that failed in that time period, in the mid-
     1980's, that if any Senator on the committee wanted to come 
     in and ask questions about that particular institution, that 
     they had a right in law to do so. We did not foresee the 
     Madison case at that time, but it applies precisely to the 
     Madison case and every other case out of that time period. 
     (Cong. Rec. S3153, March 17, 1994).

  To the degree the chairman's letters are open to an interpretation 
that would imply the possibility that they have been requested by the 
administration to bolster its efforts to deny information to the 
Congress and thereby the public, at issue would be a collusive effort 
by the majority party in the Congress to aid and abet the executive 
branch in its concerted effort to deny disclosure of information 
related to legitimate congressional oversight.
  In this regard, a letter recently copied to Representative William 
Clinger, ranking member of the Government Operations Committee, 
evidences a comparable approach in another committee of Congress [Tab 
E].
  It is the minority's position that executive branch witnesses must 
address their obligations to respond to legitimate oversight requests 
and legitimate inquiries on the subject of hearings as required by the 
law and the Constitution, not in conjunction with any arbitrary desire 
of a chairman to deny discussion on a subject the executive branch 
would rather not forthcomingly address. The minority party, has a 
baseline assumption that officials of the U.S. Government will comply 
with the law and, when appearing before a committee of Congress, abide 
by the Code of Government Ethics for Federal employees to ``Uphold the 
Constitution, laws, and regulations of the United States and all 
governments therein and never be party to their evasion.'' [Public Law 
No. 96-303, July 3, 1980, 94 Stat. 855].
  The constitutionally-derived obligation of oversight cannot be short-
circuited at the whim of the congressional majority. It is just as much 
the duty of the minority party, as the majority. Indeed, in real life 
circumstance as evidenced in this particular incident, oversight may in 
practice imply a greater obligation on the party out of power than the 
party in control of the executive branch.
  Hodding Carter, the distinguished journalist from Mississippi, 
recently noted that southerners of virtually all philosophical stripes 
recognized a little or a lot of truth in certain northern concerns 
about discrimination that existed in the South in the heyday of civil 
rights activism. But with understandable resentment all felt that 
northerners had a duty to look a little more assiduously in their own 
backyards. In this probe of Whitewater, I believe an outsider might 
conclude that the single party concentration of political power in 
Arkansas may be in need of review that the shadow of Lyndon Johnson and 
Huey Long may have been cast to greatly on a former governorship. But 
as a northerner, I am obligated to note that my primary responsibility 
is my backyard, in this case the body to which I am elected to serve. 
While I believe it would be unfair to suggest that one of America's 
great political parties is more honest than the other, I believe the 
concerted effort to avoid accountability and full disclosure in the 
Whitewater incident, and the unfortunate institutional precedents in 
process of being established, reflect attitudes more associated with 
single party governance of closed than open societies. Competition is 
the American way. When single party dominance is long and deep, 
arrogance associated with power creeps incontestably into the system. 
Whitewater, in the end, may tell more about Congress than the executive 
branch.
  In this context, the minority raised concerns about the manner in 
which the RTC oversight hearing scheduled this week might have been 
conducted. Nevertheless, the minority was disappointed the hearing was 
abruptly postponed.
  Postponement of the hearing by the majority raises, above anything 
else, the issue of compliance with the law. Compliance with the law is 
not a matter of convenience or discretion. The majority party has no 
prerogative to avoid capriciously its legal obligations.
  Hearings mandated by statute were to have occurred by December 3, 
1993. It is a statutory obligation of the majority in the legislative 
branch to conduct on a timely basis RTC oversight; it is the statutory 
obligation of the executive to cooperate with Congress and comply with 
its legal responsibilities.
  The negotiations this week between leaders of the House which led to 
the passage of a bipartisan resolution expressing the sense of the 
House as to the need to hold bipartisan hearings are promising. The 
subsequent statements by the Speaker that these discussions were of the 
``possibility of hearings, not a concession that hearings are not 
necessarily going to take place,'' is disappointing. The majority that 
an obligation to ensure the decision to postpone indefinitely RTC 
hearings does not amount to yet another example of Congress not 
applying the law to itself.
  With regard to a possible hearing, let me stress the minority has 
offered to cooperate fully with the special counsel. We have 
transferred substantial information to his office. We have given him 
our proposed witness list and offered to support a delay in the day of 
hearings provided under House rules to the minority to allow him a 
chance to depose witnesses first. For his part, the special counsel, in 
a meeting on March 17, 1994, with the minority, said that he would not 
impede in any manner executive branch testimony and that he would not 
stand in the way of an RTC oversight hearing. Mr. Fiske also stated 
that he did not object to the disclosure of copies of documents to 
Congress, other than White House documents. The existence of a special 
counsel appointed in the Madison case cannot be used as a rationale to 
avoid providing RTC oversight information to Congress.
  Congress and prosecuting attorneys have differentiated roles, but 
they are by no means incompatible. In fact, they are generally 
complementary. Indeed, in the Banking Committee hearings over the past 
decade on institutions such as Lincoln--Charles Keating, and 
Silverado--Neil Bush, the Justice Department had tandem investigations 
underway. Hearings almost always reveal knowledge and perspective that 
is helpful to prosecutors. It was, after all, Senator Ervin's committee 
that revealed the existence of the Watergate tapes and it was the 
recent Senate hearing that revealed improper contacts between executive 
branch agencies and the White House. The major recent exception where a 
prosecutor was undercut by Congress involved excessive zeal to 
embarrass Presidents Reagan and Bush that caused a committee to offer 
immunity to certain witnesses in the Iran Contra people. But the more 
general proposition is that constraining a congressional inquiry has 
the effect of reducing knowledge, thus reducing prosecutorial 
discretion.
  Mr. Speaker, in a country in which process is our most important 
product, it is the belief of this Member that the precedents 
established in this investigation are more important than the 
investigation itself. Nevertheless, I come to the floor this afternoon 
to present to the attention of the House and the American people some 
findings, with supporting documentation, the Minority has uncovered in 
its ongoing investigation of the Whitewater/Madison affair.
  Accordingly, I would like to review in both a perspective and 
information dispensing sense the Madison/Whitewater issue and divide 
the remainder of my discussion in two categories: what happened and how 
the administration has responded.
  On the landscape of political scandals Whitewater may be a bump, but 
it speaks mountains about me-generation public ethics as well as single 
party control of certain States and the U.S. Congress.
  In a nutshell, Whitewater is about the arrogance of power--
Machiavellian machinations of single-party Government. It all began in 
the late 1970's when a budding S&L owner named James McDougal formed a 
50-50 real estate venture with a young politician, the then Attorney 
General of Arkansas, Bill Clinton. In this venture called Whitewater, 
the S&L owner and S&L affiliated entities provided virtually all, 
perhaps, all, the money; the Governor-in-the-making provided his name.
  Over the years, the company received infusions of cash from the S&L 
as well as from a small business investment corporation which diverted, 
allegedly at the Governor's request, federally-guaranteed funds from a 
program designed for socially and economically disadvantaged people to 
the Governor's partners and thence, in part, to Whitewater.
  Some of these funds were used to pay off personal and campaign 
liabilities of the Governor; some to purchase a tract of land from a 
company to which the State had just given a significant tax break. 
Whitewater records have apparently been largely lost. A review of the 
numerous land transactions, however, raises questions of what happened 
to the money that came into the company and a review of the President's 
tax records raises questions about tax deductions that were taken and 
income that may not have been declared.
  Under the governorship of Bill Clinton, Jim McDougal was named a 
Gubernatorial aide to serve principally liaison to the Economic 
Development, Commerce, and Highway and Transportation Departments; the 
first lady of Arkansas was hired to represent the S&L before State 
regulators; the president of the S&L was placed on the State S&L 
commission; an attorney who represented the S&L was named the State S&L 
regulator; the S&L received rent from State agencies; Whitewater had 
roads constructed using a State agency program and State funds; and the 
S&L was allowed to operate, despite being insolvent for an extended 
period, providing millions in loans and investment dollars to insiders 
and the Arkansas political establishment.
  Under the governorship of Bill Clinton, the S&L was allowed to grow 
25-fold until Federal regulators forced its closing, at which time 
taxpayers picked up the tab for losses that amounted to approximately 
50 percent of the institutions's deposit base.
  Under the governorship of Bill Clinton, the total number of State-
chartered savings associations declined dramatically. Over the period 
December 1979 to December 1992, the number of stock State-chartered 
thrifts in Arkansas declined from the 33, with assets of $961,002,000 
to 3, with assets of $146,072,000. Viewed another way, the amount of 
assets available to support home mortgage lending for the people of 
Arkansas declined.
  The story of Whitewater is thus part and parcel the story of the 
greatest domestic policy mistake of the century--the quarter-trillion 
dollar S&L debacle. It is the story of a company which in one sense was 
a simple real estate development venture, but in another was a vehicle 
used to spirit federally insured deposits from an S&L and compromise a 
significant political figure.
  In the largest series of bank robberies in history, which 
precipitated an industry bail out larger than the taxpayers provided 
Lockheed, Chrysler, and New York City times a factor of 10, it is fair 
to ask: ``What happened? Who is responsible.''
  An answer to these inquiries requires an understanding that those 
accountable are not only a few negligent and corrupt S&L owners, but 
attorneys, accountants, State and Federal legislators, regulator and 
assorted public officials. As wide ranging as the responsibility is, 
however, it is a mistake to be so glassy eyed as not seek lessons for 
the future through a demand for individual accountability for breaches 
of law and ethics in the past.
  Macroeconomics aside, public responsibility for the S&L debacle is of 
a tripod nature, involving: First, the conflict-ridden role of Congress 
in passing loose laws; second, the ideological mistake of the Reagan 
administration in urging deregulation in an industry which requires 
responsible standards; and third, the culpability of a small number of 
State governments, such as in California, Texas, Louisiana, and 
Arkansas, which failed to rein in high flying State-chartered, State-
regulated institutions, which because of the Federal nature of deposit 
insurance, precipitated a massive transfer of wealth from States with 
responsible governments to those without.
  In Arkansas it is impressive how the Federal Government was obligated 
to close more than 80 percent of State-chartered S&L's in the 1980's 
and how large taxpayer losses were in relation to the State's S&L 
deposit base. The failure of the Clinton administration in Little Rock 
to fulfill its responsibility to police State financial institutions 
had the effect of increasing tax burdens on citizens of Arkansas as 
well as other States.
  While taxpayers at the national level were forced to pick up the tab 
for the mistakes of politicians in whose elections they could not vote, 
citizens in States like Arkansas were doubly shortchanged. Not only did 
they have to share in eventual bail out costs, but when their home-
based financial institutions frittered away the hard earned deposit 
savings of the their State to insiders, fewer resources were made 
available to potential homeowners and minority entrepreneurs.
  What the Keating-5 scandal was all about was the attempt of an S&L 
owner to compromise through political contributions significant 
political players, in this case five Senators, to influence regulators 
to keep an insolvent, corruptly run, institution from being closed. 
What makes Governor Clinton's involvement with a company which helped 
breach the vaults of an Arkansas S&L philosophically at least equal to, 
but in reality more troubling than the Keating model is that not only 
did the institution's management organize conflict-ridden fund-raising 
endeavors for the key politician in the State, but through Whitewater 
it put the Governor in a compromising personal finance position as 
well.
  What is extraordinary is the hypocrisy of the circumstance. The 
following 1991 announcement statement of Governor Clinton speaks for 
itself:

       For 12 years of this Reagan-Bush era, the Republicans have 
     let S&L crooks and self-serving CEO's try to build an economy 
     out of paper and perks instead of people and products. They 
     stack the deck in favor of their friends at the top and tell 
     everybody else to wait for whatever trickles down.

  Despite the rhetoric it is remarkable how time after time in the 
1980's, alleged defenders of the little guy in American politics found 
themselves advancing the interests of a small number of owners of 
financial institutions which were run as private piggy banks for 
insiders. The intertwining of greed and ambition turned democratic 
values upside down.
  In our kind of democracy ends simply don't justify means. Just as a 
conservative, who may despise government, has no ethical right not to 
pay taxes, a liberal has no ethical basis to put the public's money in 
his own or his campaign's pocket just because he may have the arrogance 
to believe he is advancing a political creed that is in the public's 
interest.
  Why does all this matter?
  Here, it would perhaps be appropriate to paraphrase the great 
Illinois Senator, Ev Dirksen: a few thousand here and a few thousand 
there and pretty soon it adds up to a real scandal. Put another way, an 
ethical lapse here and an ethical lapse there and pretty soon it adds 
up to a character deficit.
  I have never known anyone in public life better able to put 
embarrassing episodes behind him than Bill Clinton. Accordingly, I 
couldn't have been more surprised by the discombobulation of the 
administration at the minority's restrained request last November for 
hearings and full disclosure.
  As in most serious public scandals, coverups can prove as troubling 
as acts at their source.
  Much press attention has centered in recent weeks on the revelations 
of improper contact between employees of independent Federal agencies 
and the White House. The question of whether a heads up was appropriate 
is of significance. More so, is whether the line between a heads up and 
coverup was crossed.
  By background, for several years a group of criminal investigators 
for the RTC in Kansas City reviewed the failure of Madison Guaranty 
Savings & Loan in Little Rock and came to the conclusion criminal 
referrals were appropriate. In the last week of September 1993, they 
sent copies of their referrals to Washington. Within a few days of 
receipt of the referrals from the Kansas City office, RTC Washington 
officials visited the White House. Within a few weeks, in an 
unprecedented change of procedure, Washington demanded to review all 
Madison referrals. Within a few months, a senior Kansas City criminal 
investigator was removed from the case. Within a few more months, 
officials from RTC Washington visited Kansas City to pass on the 
determined message that senior RTC officials in Washington wanted it 
understood that they wished to claim Whitewater was not responsible for 
any losses at Madison.
  Courageously, Kansas City investigators refused to allow Washington 
RTC objections to change the content of the referrals they sent in the 
second week of October 1993, to the Justice Department.
  Courageously, Kansas City investigators refused to back the 
Washington position that Madison's losses were unrelated to Whitewater 
and pointed out to their superiors that in one intensely reviewed 6-
month period alone approximately $70,000 was transferred from Madison 
and Madison affiliated companies to Whitewater.
  Courageously, Kansas City investigators have sought whistleblower 
protection rather than comply with the Washington RTC gag order that no 
one form Kansas City could speak with Special Counsel Fiske without 
clearance through and accompaniment of Washington RTC officials.
  The briefing of the White House by high ranking Department of 
Treasury and RTC employees must be understood in the context of the 
development and transmittal to the Justice Department of these 
referrals and in the context of the possibility Kansas City was in the 
process of developing further referrals.
  There are many elements of the Whitewater affair that are a bit 
esoteric. But the revelations that U.S. Government officials briefed 
key White House aides on potential legal actions which independent 
regulatory agencies might be obligated to take implicating but not 
charging the President and First Lady subvert one of the fundamental 
premises of American democracy--that this is a country of laws and not 
men.
  In America no individual, whatever his or her rank, is privileged in 
the eyes of the law. No public official has the right to influence 
possible legal actions against him or herself. For this reason agencies 
of the Government as well as the White House have precise rules that 
govern their employees.
  The following standards--31 CFR Sec. 0.735-30--apply to the 
Department of Treasury:

       An employee should avoid any action . . . which might 
     result in, or create the appearance of . . .
       (2) Giving preferential treatment to any person; . . .
       (4) Losing complete independence or impartiality;
       (5) Making a Government decision outside official channels; 
     or
       (6) Affecting adversely the confidence of the public in the 
     integrity of the Government.

  Similarly, the following standards contained in 12 CFR Sec. 1605.7 
apply to RTC employees:

       No employees shall engage in any action, which might result 
     in, or create the appearance of . . .
       (b) giving preferential treatment to any person; . . .
       (d) losing complete independence or impartiality;
       (e) making an RTC decision outside official channels; or,
       (f) adversely affecting the public's confidence in the 
     integrity of the RTC.

  Likewise, the following standards apply to the White House--3 CFR 
Sec. 100.735-4:

       In all circumstances employees shall conduct themselves so 
     as to exemplify the highest standards of integrity. An 
     employee shall avoid any action, whether or not specifically 
     prohibited by this subpart, which might result in, or create 
     the appearance of:
       (1) Using public office for private gain;
       (2) Giving preferential treatment to any person; . . .
       (4) Losing complete independence or impartiality;
       (5) Making a Government decision outside official channels; 
     or
       (6) Affecting adversely the confidence of the public in the 
     integrity of the Government.

  Perhaps laws have not been broken, but seldom have the public and 
private ethics of professionals in the White House and executive 
departments and branch agencies been so thoroughly devalued.
  The point of all this is that there is a disjunction in this 
administration between public policy and private ethics. Americans 
abhor privilege; hypocrisy gnaws at the American soul; it leaves a 
dispiriting residue of resentment.
  What is also extraordinary is the absence of simple truth.
  Administration claim: Whitewater caused no losses to Madison.
  Fact: As reflected in the minority-developed charts and evidenced by 
supporting documentation, Madison and affiliated companies transferred 
significant resources to Whitewater. In addition to being a modest-
sized real estate company, with a cash flow derived from land sales, 
Whitewater appears to be one of a dozen so companies with direct or 
indirect access to Madison and its taxpayer guaranteed deposits.
  Administration claim: The Clintons lost money in Whitewater.
  Fact: To have lost in Whitewater implies that the Clintons invested 
sums which were unrecovered. Their Whitewater partner, James McDougal, 
claims at most the Clintons over the years put in $13,500 in 
Whitewater. The minority has provided evidence that one land 
transaction alone returned more than this amount to the Clintons and 
published reports indicate tax deductions of some value were taken. The 
Lyons report, as well as a review of land sales, indicates substantial 
sums were taken out of Whitewater over the years. It is not clear how 
disbursements were arranged. What is clear is that infusions of capital 
from land sales, from Madison-affiliated entities and possibly from 
others appear to have covered loans the company and the Clintons took 
out. The company may have had a negative value when the Clintons sold 
their half interest in 1992, but that neither means the Clintons 
themselves lost money, nor that questions ought not be asked about how 
direct or contingent liabilities may have been disposed of as late as 
1992.

  Administration claim: The President and his staff would fully 
cooperate with Congress.
  Fact: The executive branch is actively working to prevent full 
disclosure of documents and committee access to witnesses.
  Administration claim: It has done nothing wrong in relation to the 
RTC investigation into the failure of Madison and is fully cooperating 
with Special Counsel Fiske's probe.
  Fact: Officials of an independent regulatory agency--the RTC--
immediately notified the White House of the probe of Madison by its 
Kansas City office and attempted to put in place procedural techniques 
to undercut the traditional independence of its regional offices.
  Fact: In January 1994, RTC Washington met with Kansas City staff. 
After the meeting the Kansas City office filed a formal complaint with 
Washington RTC.
  Fact: On February 2, 1994, the day Roger Altman briefed the White 
House on Madison Guaranty, RTC senior attorney, April Breslaw visited 
the Kansas City office and said that Washington would like to say that 
Whitewater caused no losses to Madison. Kansas City employees protested 
that this was not the case.
  Fact: On September 29, 1993, before the new criminal referrals were 
sent to the Justice Department, Treasury General Counsel Jean Hanson 
briefed White House Counsel on them. Nine days after the meeting, the 
referrals were sent to the Justice Department. On October 14, Jean 
Hanson with Secretary Bentsen's press secretary and chief of staff met 
with Presidential advisors ostensibly to discuss press inquiries 
related to Madison Guaranty.
  Fact: On February 2, right after the appointment of Special Counsel 
Robert Fiske, Roger Altman gave the White House a heads-up briefing on 
Madison. At the Senate oversight board hearing, Roger Altman revealed 
his February 2 meeting, but no others. Several days later, the 
September and October White House briefings were revealed. On March 9, 
the Washington Post reported that there were numerous other contacts 
between the Treasury and the White House on Madison. After subpoenas 
are issued it is revealed that there are over 3,500 pages of 
documentation surrounding these contacts which the White House terms as 
inconsequential.

  Fact: After the appointment of Special Counsel Fiske, Washington RTC 
officials imposed censorship guidelines on Kansas City RTC employees. 
No discussion with Fiske could be made without going through 
Washington. No meetings between Kansas City office and Fiske could take 
place without accompaniment of Washington officials. No materials could 
be forwarded without going through Washington. All information 
concerning attorney-client privilege was to be redacted, with 
Washington RTC determining the scope.
  Administration claim: No fundraising improprieties occurred.
  Fact: On April 4, 1985, Jim McDougal hosted a fundraiser for Governor 
Clinton. The Clinton's repeatedly asked McDougal to host the fundraiser 
to pay off the $50,000 personal loan that Clinton had taken out in the 
final weeks of his 1984 campaign. The question at issue is whether some 
of the money appears to have been diverted from Madison Guaranty, which 
would then, with the failure of Madison, imply deferred Federal 
financing of a gubernatorial election. For example, one cashier's check 
for $3,000 was made in the name of Charles Peacock III, then a 24-year-
old college student who disclaims any knowledge of having made a 
contribution. Mr. Peacock's father was a major Madison borrower and 
served at one time on Madison's board. Other checks that the RTC is 
reviewing include a $3,000 check from the late Dean Landrum, an 
employee of Charles Peacock, and one from Susan McDougal. In the former 
Governor's defense, candidates are not always in a position to verify 
their campaign contributions.
  Mr. Speaker, the President's former partner, Jim McDougal, in a 
number of occasions has contested the assertion that no resources were 
taken from Madison Guaranty and its related entities and given to 
Whitewater. In an AP story on February 4, 1994, and on the ``David 
Brinkley Show'' on March 13, 1994, he specifically raised concerns that 
Madison Marketing was not owned by Madison Guaranty, but was instead a 
sole proprietorship owned by his former wife. He has cited documents 
filed with the Arkansas secretary of state's office to buttress his 
claim.

  Mr. McDougal apparently believes there are subtleties about the 
nature of Madison Marketing that need clarification. Mr. McDougal gives 
great credence to the circumstance that at some point Madison Marketing 
may have been operating as an intended proprietorship of his wife, but, 
whether this is true, this appears to be a distinction without a 
difference, form over substance. The overwhelming perspective as 
contained in the 1986 Federal Home Loan Bank Board Report of 
Examination is that all Madison Marketing resources were derived from 
Madison Guaranty or its subsidiaries. Any money transferred to 
Whitewater from Madison Marketing would thus have had as its source the 
S&L. The 1986 FHLBB exam, upon which the earlier staff memo on this 
subject was based, states:

       A. Objectionable Conflicts of Interest: Conflicts of 
     interest involving James McDougal, Susan McDougal, and 
     William Henley have been detrimental to the safety and 
     soundness of the Institution. These individuals are in 
     control of the Institution (Madison Guaranty) through their 
     stock ownership. James McDougal owns 63.5 percent of the 
     outstanding Madison shares. His wife, Susan McDougal, owns 
     12.6 percent, and her brother, William Henley owns 8.5 
     percent. In addition to his ownership control, Mr. McDougal, 
     as President of the Institution's subsidiary (Madison 
     Financial), has complete control of the land development 
     projects discussed in comment.
       B. This control enabled Mr. McDougal to structure the 
     development and financing of the projects so that substantial 
     cash payments could be diverted to himself, Susan McDougal, 
     William Henley and others. These payments have directly 
     benefited these individuals, but Madison Guaranty has 
     received little or nothing in return. Though they have been 
     structured to avoid specific Insurance Regulations, these 
     payments are contrary to the general policy of the FHLBB 
     concerning conflicts of interest as stated in Insurance 
     Regulation 571.9 and FHLBB Memorandum R-19a.
       Many of these payments have been funneled through business 
     entities which are owned or controlled by the McDougals, 
     employees, relatives of employees, or close friends of the 
     McDougals and Henley.
       Madison Marketing: Madison Marketing is paid for doing all 
     the general advertising for Madison Guaranty and most of the 
     advertising for Madison Financial's land development 
     projects. All of Madison Marketing's business is derived from 
     Madison Guaranty or its subsidiaries. Since 1983 these 
     payments total $1,532,000.
       Given the evidence of Madison Marketing's invoices, it is 
     questionable how much of these advertising services are 
     actually performed by the firm. The actual work of 
     advertising, such as the design and production of commercials 
     and providing air time or newspaper space, appears to be 
     performed by others. Madison Marketing apparently just pays 
     the bills of other providers and adds a 15 percent fee of its 
     own. Examiners estimated this fee to be approximately 
     $200,000 since 1983. It would appear that Madison Guaranty 
     could have an employee perform similar work for much less 
     money.
       Mr. Latham stated that Madison Marketing made no payments 
     to any stockholders. This statement is false. As a part of a 
     test for such payments, the examiners discovered two 
     remittances from Madison Marketing to Susan McDougal which 
     total $50,000. This was a test, and there may be additional 
     payments.

  Mr. McDougal apparently believes Madison Marketing should be 
understood simply as a sole proprietorship of his wife with no ties to 
the S&L. This view is in discordance with that of the U.S. Government, 
as indicated by the FHLBB report cited above; it is also in discordance 
with a contemporaneous view of the legal situation as defined and 
described by Mr. McDougal in a July 1, 1986, memorandum from him to 
Madison guaranty's president, Mr. John Latham. In this memorandum, 
which is a copy of an original Madison document in the possession of 
the RTC and the minority of the House Banking Committee, Mr. McDougal 
asserts:

       In late January 1985, Mrs. McDougal permitted Madison 
     Marketing to become a subsidiary of Madison Financial 
     Corporation.

  In addition, Mr. Jeff Gerth of the New York Times has reported on 
March 8, 1992, an earlier instance in which Madison Marketing 
transferred resources to Whitewater. Mr. Gerth reported:

       Whitewater's check ledger shows that Whitewater's account 
     at Madison was overdrawn in 1984, when the corporation was 
     making payments on the Clinton's loan. Money was deposited to 
     make up the shortage from Madison Marketing, an affiliate of 
     the savings and loan that derived its revenues from the 
     institution, records also show.

  In addition, David Hale and his attorney Randy Coleman have asserted 
in recent days that it was proceeds of an $825,000 Madison loan that 
was used to leverage SBA funds and to make the $300,000 loan to Susan 
McDougal, of which $110,000 was deposited to Whitewater.
  This evidentiary material coupled with the April 17, 1985, minutes of 
Madison Financial's board authorizing a transfer of $30,000 
from Madison Financial to Whitewater, the memo of L. Jean Lewis of the 
Kansas City RTC office showing over a 6-month period reviewed that 
approximately $70,000 was transferred from Madison or affiliated 
entities to Whitewater, plus other more confidential RTC material in 
our possession indicates there is every credible reason to believe that 
Madison Guaranty through affiliated entities did transfer money to 
Whitewater.

  Furthermore, records filed with the Arkansas Secretary of State's 
office show that Mr. McDougal, as president of Madison Financial 
Corp.--a subsidiary of Madison Guaranty--on July 26, 1986, filed an 
application for registration of fictitious name. The application was 
for Madison Financial to do business as Madison Marketing. This 
document does not represent incorporation papers. This application 
appears to be in response to the 1986 Federal Home Loan Bank exam which 
noted that with regard to Madison Marketing and Madison Real Estate, 
Madison Financial had not registered as a ``doing business as'' in the 
county records.
  The effect of this statement with its supporting documentation is to 
evidence that:
  First, Whitewater may have begun as a legitimate real estate venture 
but it came to be used to skim, directly or indirectly, federally 
insured deposits from an S&L and a Small Business Investment 
Corporation. When each failed, the U.S. taxpayer became obligated to 
pick up the tab;
  Second, the family of the former Governor of Arkansas received value 
from Whitewater in excess of resources invested;
  Third, taxpayer guaranteed funds were in all likelihood used to 
benefit the campaign of a former Governor;
  Fourth, the independence of the U.S. Government's regulatory system 
has been flagrantly violated in an effort to protect a single American 
citizen; and
  Fifth, Congress and the Executive are employing closed society 
techniques to resist full disclosure of an embarrassing circumstance, 
with unfortunate precedent setting ramifications.
  Last month a BBC reporter asked me if we Americans weren't making too 
much of this scandal. He raised a fair question. Compared with petty 
potentates around the world, who routinely walk off with millions and 
in some cases billions, conflicts of interest in American politics are 
of petty variety. In this case, however, we have a situation where a 
multithousand-dollar conflicts of interest led to a multimillion-dollar 
hit on the taxpayer. That is the meaning to the failure of Madison 
Guaranty. That is also the meaning of the Small Business Investment 
Corporation called Capitol.
  It is simply not appropriate to shrug it off and say that this is the 
way things are done in small States. They aren't in Nebraska, South 
Dakota, or Iowa. It is simply not appropriate to say it isn't a Federal 
issue. It is. The U.S. taxpayer has lost millions; homeowners in 
Arkansas have lost institutions that were established to serve their 
needs; minorities throughout the country cannot lightly shrug off yet 
another instance in which a program designed to give them a crack at 
the American dream was redirected to serve the investment ego a State 
political establishment.

  It is suggested by the majority that we have better things to do 
around here. There again is some truth to this. The minority also wants 
to get on with the business of health care, welfare reform, crime 
legislation. Indeed, we pledge to be constructive and are not blocking 
any congressional consideration of these issues. But, in a larger 
sense, it should be understood that these--we have better things to 
do--laments suggest that ethics, governmental integrity, and the 
possible misuse of the public's money should be secondary 
considerations--something to worry about only when we have time. In a 
democratic system, built and maintained on the confidence of the 
people, placing such considerations last on the list of priorities is a 
highly dubious game. Nothing works over the long haul if the public 
loses confidence in its governmental institutions and the people who 
operate those institutions. The task of keeping the people's confidence 
may not be pretty or pleasant, but it is a first priority in our 
system--not a last priority as all too many are suggesting today.
  Whitewater is less about the issues of the day than it is the ethics 
of our time. It is a central issue not because it is big, but precisely 
because it is small.
  The way we in America keep our scandals from becoming too big is by 
holding people accountable when the amounts of money at issue are 
relatively small. It is the principles at issue, not the dollar amounts 
that matter.
  In conclusion, let me stress that the most difficult issue to deal 
with is the question of proportionality. When the minority made its 
restrained request for hearings last November, I suggested that while 
there was fire with the smoke, Whitewater appeared to be more a camp 
than forest fire. I now believe the fire has spread to the grass and is 
heading to the trees but that it is still not too late to put it out 
with full disclosure and full accountability. In this regard, I 
suggested in a December, Washington Post editorial that when breaches 
of law or public ethics occur, options often exist as to whether civil 
or criminal remedies are appropriate. I presumptuously concluded then 
and maintain now that there is no reason not to proceed with civil 
accountability in a civil way. The last thing this country needs is a 
year long trial or travail for the President of the United States. It 
would divide the country and be unfair to the public as well as the 
President.
  Accordingly, I have pledged to the President's counsel as well as to 
the special counsel that I will do my best to put the issue behind once 
disclosure is provided. Accountability is in order; a constitutional 
crisis is not. The Presidency should neither be jeopardized nor 
debilitated. Rather than high crimes and misdemeanors, the issue today 
relates to high improprieties and breaches of the public trust.

                  Additional Supporting Documentation


               statement of the honorable james a. leach

       1. Notes of Conversation between L. Jean Lewis and April 
     Breslaw, February 2, 1994. ``(T)he `head people', would like 
     to be able to say that Whitewater did not cause a loss to 
     Madison, but the problem is that so far no one has been able 
     to say that to them.'' Describes losses to Madison caused by 
     Whitewater.
       2. Board of Directors Minutes, Madison Financial 
     Corporation, April 17, 1985. ``RESOLVED, that the Corporation 
     pre-pay to Jim McDougal $30,000.00 of his annual bonus in 
     recognition of the profits of the prior year and that said 
     bonus is to be paid directly to Whitewater Development.''
       3. Application for Registration of Fictitious Name, 
     Applicant--Madison Financial, Fictitious Name--``Madison 
     Marketing'' (July 25, 1986).
       4. Chronology of Criminal Investigation.
       5. Letter of September 1, 1992 from L. Richard Iorio (RTC-
     KC) to Steve Irons (FBI) transmitting criminal referral.
       6. Letter of September 1, 1992 from L. Richard Iorio (RTC-
     KC) to Charles A. Banks (DOJ) transmitting criminal referral.
       7. RTC Internal Memorandum, May 3, 1993. Background remarks 
     and conversation with AUSA Bob Roddey's office re: Madison 
     Guaranty Savings referral.
       8. RTC Internal Memorandum, May 19, 1993. Additional 
     conversation with Office of Legal Counsel for U.S. 
     Attorney's, U.S. Justice Department, Washington, D.C. No 
     record of Madison criminal referral at Washington DOJ.
       9. RTC-KC E-Mail, May 19, 1993. Madison matter forwarded to 
     Donna Henneman in ``Legal Counsel.'' Referral submitted to 
     that office ``because of the political ramifications and 
     political motivations.''
       10. RTC-KC E-Mail, May 26, 1993. Follow-up call from Donna 
     Henneman (DOJ). RTC advised by an FBI agent in Little Rock 
     that it was a ``very solid case of check kiting, and was 
     highly prosecutable.'' Henneman was growing increasingly 
     frustrated by the situation, because she had seen the 
     information, knew that it had come in, and couldn't 
     understand why she was having such a hard time tracking where 
     the referral and exhibits had gone.
       11. RTC-KC E-Mail, June 8, 1993. Conversation with Donna 
     Henneman (DOJ). Madison Referral has reappeared on her desk. 
     Criminal Division has sent memo to Doug Frazier (in Depty 
     Atty General Heyman's office) advising him that there was 
     ``no identifiable basis for recusal of the U.S. Attorney in 
     the Eastern District of Arkansas.'' Referral sent to Frazier 
     for review and final decision.
       12. RTC-KC E-Mail, June 23, 1993. Conversation with Donna 
     Henneman (DOJ). Package returned from Frazier. Frazier 
     appointed U.S. Attorney in Florida.
       13. RTC-KC E-Mail, June 23, 1993. Further Conversation with 
     Donna Henneman (DOJ). Spoke with Doug Frazier. Decision made 
     to return the referral back to the Arkansas U.S. Attorney. No 
     basis for recusal.
       14. RTC-KC E-Mail, June 29, 1993. Source indicates Madison 
     referral has been returned to Little Rock. Acting U.S. 
     Attorney will not act on referral. It is being held until 
     U.S. Attorney designee Paula Casey takes office.
       15. RTC-KC E-Mail, September 23, 1993. Conversation with 
     Donna Henneman (DOJ). Washington DOJ would like to be copied 
     on all future transmittal letters concerning Madison 
     referrals with an additional one paragraph summary of the 
     content of the referrals with the transmittal letters, so 
     that Henneman will be aware of those with ``sensitivity 
     issues.''
       16. RTC-KC E-Mail, September 29, 1993. Conversation with 
     Donna Henneman (DOJ). DOJ would like copies of all future 
     Madison referrals sent to Washington in addition to sending 
     to U.S. Attorney in Little Rock. Henneman will confirm this 
     in writing.
       17. RTC-KC E-Mail, September 29, 1993. Conversation with 
     Donna Henneman (DOJ). Washington DOJ withdrawing request for 
     referrals to be sent directly to Washington, but would still 
     like copies of transmittal letters with addendum summary 
     paragraph.
       18. RTC-KC E-Mail, October 26, 1993. Conversation with 
     FDIC-Memphis concerning Exam Reports.
       19. RTC-KC E-Mail, October 27, 1993. Conversation with 
     Donna Henneman (DOJ). Inquiry on whether declination letter 
     had arrived from Little Rock U.S. Attorney.
       20. Letter of October 27, 1993 from Paula J. Casey (U.S. 
     Attorney) to L. Jean Lewis (RTC). Declination letter on the 
     Madison referral.
       21. Letter of November 1, 1993 from L. Jean Lewis (RTC) to 
     Paula J. Casey (U.S. Attorney). Confirmation of declination 
     letter and the stipulation from October 27th letter that the 
     matter was concluded prior to the beginning of Paula Casey's 
     tenure and that the RTC had never been advised of such 
     result. Chronology of correspondence between RTC and DOJ.
       22. RTC-KC E-Mail, November 10, 1993. Notice of new RTC 
     lead investigator on Madison. L. Jean Lewis removed as lead 
     investigator. ``The Powers That Be have decided that I'm 
     better off out of the line of fire . . .''
       23. RTC-KC E-Mail, November 15, 1993. Transmittal of white 
     paper outlining chronology of events related to 1992 Madison 
     referral. Challenges news article indicating that decision to 
     decline Madison referral had been prior to Paula Casey's 
     appointment.
       24. RTC-KC E-Mail, November 15, 1993. Discussion of meeting 
     with Donald MacKay. ``He's coming here to evaluate us, our 
     work, and to try and decide just how good this case is, and 
     how he can best deal with a very sensitive political 
     situation.''
       25. Letter of December 21, 1993 from Michael Caron (RTC) to 
     Bill Houston (FDIC-Memphis). Seeking information on banks 
     involved in loan swapping.
       26. RTC-KC E-Mail with attachment, January 6, 1994. 
     Discussion of contact with reporter.
       27. RTC Memorandum of January 14, 1994 from Jack Ryan to 
     RTC Vice Presidents and Assistant Vice Presidents. 
     Requirement that the collection and distribution of all 
     information and material responsive to requests concerning 
     Madison be coordinated through RTC-Washington.
       28. RTC-KC E-Mail, January 25, 1994. Establishment of 
     Madison review team.
       29. RTC-KC E-Mail, February 7, 1994. Conversation with 
     Little Rock U.S. Attorney's office. ``(H)e'd spoken to Jeff 
     Gerrish recently, and that Gerrish was `absolutely astounded' 
     that nothing more was ever done criminally with Madison, 
     beyond the Castle Grande transaction.
       30. RTC-KC E-Mail, January 5, 1994. RTC Washington review 
     of Madison investigators. Response memo from supervisor 
     stating, ``FYI. This is way out of line. I have already 
     contacted WDC and filed a formal complaint.''
       31. Letter of October 10, 1983 from C.J. Giroir, Jr. (Rose) 
     to James B. McDougal. Pursuant to discussion with Hillary 
     Clinton enclosing a billing for Madison Bank & Trust dated 
     December 23, 1981.
       32. Memorandum to Governor Bill Clinton from Jim McDougal, 
     February 7, 1985. ``Kathy called yesterday to ask for my 
     recommendations for two people to fill the vacancies on the 
     State Savings and Loan Board. * * * Bill, we are down to only 
     about 15 State-chartered savings and loan institutions and I 
     am about the only one around who has any interest in this 
     board.''
       33. Letter of December 12, 1984 from James B. McDougal 
     (Whitewater Development Co.) to Ron Proctor (Citizens Bank). 
     ``I have been unsuccessful in trying to meet with Bill and 
     Hillary to sign the vote renewal. I have forwarded to them by 
     messenger this morning the note and an envelope with which to 
     forward it to you. Each month we will deposit into our 
     account at Flippin an amount sufficient to cover the monthly 
     payment.''
       34. Memorandum to John Latham from Jim Mcdougal, April 18, 
     1985. ``I want this preferred stock matter cleared up 
     immediately as I need to go to Washington to sell stock.''
       35. Memorandum to John Lathan from Jim McDougal, February 
     19, 1985. ``Proceed with your idea on the subordinated notes. 
     We need to make a decision on Madison Bank & Trust.''
       36. Memorandum to John from Jim, January 7, 1985. ``You, 
     Greg, and I need to discuss Securities License. First South 
     has one on by its Service Corporation.''
       37. Memorandum to John Lathan from Jim McDougal, July 11, 
     1985. ``I need to know everything you have pending before the 
     Securities Commission as I intend to get with Hillary Clinton 
     within the next few days.''
                                  ____


Notes From the Conversation Between RTC Senior Criminal Investigator L. 
 Jean Lewis and FDIC Attorney April Breslaw on February 2, 1994, From 
                Approximately 3:50 p.m. Until 4:35 p.m.

       April stated that ``the people at the top'' keep getting 
     asked about Whitewater, which seems to have become a catch 
     all phrase for Madison and it's related investigations. She 
     said that eventually ``this group'' is going to have to make 
     a statement about whether or not Whitewater caused a loss to 
     Madison, but the fact that Whitewater had no loan at Madison 
     provided less potential for a loss. April stated very clearly 
     that Ryan and Kulka (?), the ``head people'', would like to 
     be able to say that Whitewater did not cause a loss to 
     Madison, but the problem is that so far no one has been able 
     to say that to them. She felt like they wanted to be able to 
     provide an ``honest answer'', but that there were certain 
     answers that they would be ``happier about, because it would 
     get them off the hook.''
       April felt that it would have been difficult to determine 
     exactly what happened with the Whitewater account, because so 
     many checks had gone in and out of the account, and made a 
     reference to the end resulting netting itself out. She asked 
     about Greg Young's work papers on the Maple Creek Farms 
     reserve for development analysis, and how it didn't seem to 
     have any apparent tie to Whitewater. I concurred that it 
     didn't have any legitimately defined tie, which is precisely 
     why it was included in the referral.
       She inquired about the $30,000 check to Jim McDougal from 
     Whitewater in 5/85, and about the disposition of the funds. I 
     explained the transaction as I know it: the $30,000 had been 
     converted to a MGS&L cashier's check, which was subsequently 
     endorsed by ?????? and deposited to Riggs National Bank. I 
     explained that when the check was force paid, the Whitewater 
     account was overdrawn by over $28,000 which was then 
     subsequently covered by the payment of a $30,000 bonus from 
     MFC to Jim McDougal, deposited directly to Whitewater on 
     McDougal's orders.
       She asked how we could get to a clear cut answer as to 
     whether or not Whitewater caused a loss to Madison. I stated 
     that, as far as I am concerned, there is a clear cut loss. I 
     also stated that any attempt to extract Whitewater as one 
     entity from the rest of the McDougal controlled entities 
     involved in the alleged check kite will distort the entire 
     picture. I further pointed out that I would produce the 
     answers that were available, but that I would not facilitate 
     providing ``the people at the top'' with the ``politically 
     correct answers just to get them off the hook''.
       She asked questions about the specifics of the checks going 
     through the Whitewater account. I stated that it appeared 
     that the majority of the checks written out of the Whitewater 
     account during the window time frame were going to other 
     financial institutions to make loan payments. I also said 
     that the referral focused only on a short time frame, but 
     that if that same research were conducted for a two year 
     period, it was my belief that the losses to Madison from the 
     Whitewater account alone would easily exceed $100,000, given 
     that $80,000 had gone out of the account during the six month 
     window time frame. I further added that the end loss result 
     from the entire scam, using all 12 companies/entities, would 
     be hundreds of thousands of dollars in what were essentially 
     unauthorized loans.
       I stated that if she wanted me to tell her, unequivocally, 
     that Whitewater didn't cause a loss, I could not do that. I 
     could only reiterate the allegations contained in the 
     referral, which are based on fact, and that it is my opinion 
     and belief that Whitewater did, in fact, cause a loss to 
     Madison because of the amount of the unauthorized loans that 
     McDougal made, through the check kite, to entities in which 
     he was a primary party and beneficiary. I also pointed out 
     that this ultimately benefited his business partners--the 
     same business partners that knew they had real estate 
     ventures that were not cash flowing, but that also knew their 
     mortgages and/or notes were somehow being paid. I pointed out 
     that these business partners are intelligent individuals, the 
     majority of them being attorneys, who must have concluded 
     that McDougal was making the payments for their benefit. I 
     posed the question to her, if you know that your mortgages 
     are being paid, but you aren't putting money into the 
     venture, and you also know the venture isn't cash flowing, 
     wouldn't you question the source of the funds being used to 
     your benefit? Would you just assume that your partner was 
     making these multi-thousand dollar payments out of the 
     goodness of his heart? Wouldn't you wonder even more if you 
     knew that your business partner's main source of income, and 
     S&L, was in serious financial difficulty, which by 1985 was 
     fairly common knowledge?
       We discussed the initiation of the MGSL investigation, and 
     how evidence of the check kite came to light. I explained 
     that after reviewing a series of checks, all of which noted 
     ``loan'' in the memo field, I discerned a pattern that looked 
     like a check kite, and proceeded to trace funds through the 
     various accounts, which is a standard investigations 
     procedures. The end result was the referral alleging a 
     massive check kite. I also advised April that I had been told 
     by both the U.S. Attorney's office (Mac Dodson), and the FBI 
     (Steve Irons) that this was a highly prosecutable case of 
     check kiting. I also told her that I disputed the declination 
     of that referral on the basis of ``insufficient 
     information''. She commented that ``that's what Grand Juries 
     are for'', and I pointed out that it generally seemed to be 
     the policy of the U.S. Attorney to agree to open a case 
     before they would start Grand Jury proceedings. I also noted 
     that I found the treatment of that particular referral by the 
     Justice Department to be highly unusual. This concluded our 
     discussion.
                                  ____


               Minutes of Meeting Madison Financial Corp.

       The Board of Directors of Madison Financial Corporation met 
     on April 17, 1985, at 1:00 p.m. at the offices of Madison 
     Financial Corporation at 16th and Main Streets, Little Rock, 
     Arkansas. All directors were present. The minutes of the 
     previous meeting were read and approved as recorded.
       The first order of business, introduced by John Latham, was 
     the matter of authorizing prepayment of Jim McDougal's bonus. 
     After a full discussion, the following resolution was 
     unanimously adopted, with Jim McDougal abstaining from the 
     voting:
       ``Resolved, that the Corporation pre-pay to Jim McDougal 
     $30,000.00 of his annual bonus in recognition of the profits 
     of the prior year, and that said bonus is to be paid directly 
     to Whitewater Development.''
       There being no further business, the meeting was adjourned.
                                                James B. McDougal,
                                                         Chairman.
                                  ____


                           State of Arkansas


                   office of the secretary of state,

            Application for Registration of Fictitious Name

     To: W. J. ``Bill'' McCuen,
     Secretary of State
     State Capitol, Little Rock, AK.
       Pursuant to the provisions of Section 95 of the Arkansas 
     Business Corporation Act, (Act 576 of 1965), the undersigned 
     corporation hereby applies for the registration of the use of 
     a fictitious name and submits herewith the following 
     statement:
       1. The fictitious name under which the business is being, 
     or will be conducted by this corporation is: Madison 
     Marketing.
       2. The character of the business being or, to be conducted, 
     under such fictitious name is: Advertising and public 
     relations.
       3. (a) The corporate name of the applicant is: Madison 
     Financial Corp.
       (b) the State of incorporation is: Arkansas.
       (c) The location (giving city and street address) of the 
     registered office of the applicant corporation in Arkansas 
     is: 2124 First Commercial Building, Little Rock, AR.
       4. The applicant states that if it is a foreign corporation 
     that it is admitted to and authorized to do business in the 
     State of Arkansas.
       5. The filing fee in the amount of $10.00 is enclosed.
       Name of Applicant Corporation: Madison Financial 
     Corporation.
       Signature: James B. McDougal, President.
       Address: P.O. Box 1583, Little Rock, AR.
                                  ____


              Criminal Investigative Chronology of Events


                          march 9 to 23, 1992

       Madison Guaranty Savings & Loan ("MGSL") and it's alleged 
     ties to Whitewater Development Corporation (``Whitewater'') 
     and Bill & Hillary Clinton were reported in a 3/8/92 New York 
     Times article by Jeff Gerth. MGSL owner and board chairman, 
     James B. McDougal, had been previously tried and acquitted on 
     bank fraud charges in 6/90.
       Inquiries regarding these ties emanated from both RTC 
     Investigations in Washington, D.C., and the former Director 
     of the Tulsa Consolidated Office. The Washington inquiry went 
     through the Kansas City Regional Investigations Office to the 
     Tulsa Consolidated Investigations office, who was responsible 
     for investigating failed Arkansas thrifts. The question was 
     raised as to whether Whitewater's relationship with MGSL had 
     been reviewed, and were there any resulting losses or 
     potential criminal activity documented. As a result of this 
     inquiry, the Tulsa office criminal investigator assigned to 
     the Arkansas thrifts was asked to work with the civil 
     investigator in reviewing the completed investigative 
     findings to date. Over a two week period, the criminal 
     investigator reviewed all thrift records obtained from the 
     institution at the time of conservatorship which were stored 
     in the Tulsa office. These records included the available 
     Board Minutes, committee and subsidiary minutes, Fidelity 
     Bond policies, FHLB exams from prior years, outside audits, 
     legal correspondence files and various limited loan files. No 
     mention was found of any Whitewater relationship with MGSL.


                       march 25 to April 15, 1992

       During this time frame, Tulsa Investigations learned that a 
     former MGSL employee, subsequently (and still) an attorney in 
     the employment of a Little Rock law firm handling extensive 
     litigation in Arkansas for the TRC, had allegedly fabricated 
     at least two years of minutes for an MGSL subsidiary, Madison 
     Financial Corporation (``MFC''). The criminal investigator 
     was asked to review daily records created by the former 
     employee, who was at that time the executive assistant to 
     former MGSL president, John Latham. Latham pled guilty to one 
     charge of bank fraud in 1989. Copies of the former employee's 
     records had been shipped to Tulsa, where it would be 
     determined if further investigation was appropriate. An 
     affirmative decision was reached during the first week of 4/
     92. While this review was being conducted, the civil 
     investigator was reviewing additional Madison records stored 
     in Little Rock under the control of the post-receivership 
     assuming bank, Central Bank & Trust(``CB&T''). These records, 
     which had never been inventoried by either MGSL or CB&T, were 
     stored in a downtown Little Rock warehouse, and included, but 
     were not limited to, former officer correspondence, legal 
     files, subsidiary land development and investment files, 
     microfilm, demand deposit (checking) account records/binders, 
     cancelled checks, etc.
       Based on the findings of these concurrent criminal and 
     civil investigative reviews, the decision was made that both 
     investigators should travel to Little Rock for a more 
     extensive review of the warehoused documents. At this point, 
     the criminal investigation, which had been previously 
     scheduled for late 1992, was rescheduled to 4/92.


                          april 20 to 24, 1992

       The investigators conducted an extensive review of the 
     warehoused records, and the criminal investigator talked with 
     the FBI and U.S. Attorney's office regarding the 1990 trial 
     of former MGSL owner James B. McDougal. The criminal 
     investigator learned that the FBI was previously aware of the 
     fabricated subsidiary minutes and had taken no criminal 
     action. Tulsa Investigations management was advised 
     accordingly and that aspect of the review was suspended.
       The warehoused records revealed additional Whitewater 
     checking account statements, raising further questions about 
     the payee's on some of Whitewater's checks. A number of 
     documents belonging to the former Chief Financial Officer of 
     MGSL/MFC were located. Among these documents were several 
     accountant/ledger worksheets on numerous MFC subsidiary land 
     ``developments'', all of which were heavily subsidized by 
     MGSL. Included in one of the development worksheets marked 
     ``Maple Creek Farms'' was an item denoting a $30,000 charge 
     to Whitewater for the cost of an engineering survey; this was 
     the first indication of a relationship between MGSL and/or 
     MFC and Whitewater beyond the existence of the Whitewater 
     checking account. Original microfilm, along with pertinent 
     original documents from the warehouse, were sent back to 
     Tulsa for further investigation. Research was conducted on 
     twelve McDougal and/or McDougal business partner controlled 
     accounts, including Whitewater. Check copies were produced 
     for a two year period between 6/84 and 6/86; a standard 
     investigative procedure when tracing the flow of funds.


                         may 1 to july 15, 1992

       During the first week of 5/92, all Tulsa Consolidated 
     Office employees were advised that the Tulsa office would be 
     permanently closing at the end of 7/92. All Tulsa 
     Investigations records were shipped to the Kansas City 
     Office, thus putting the Madison investigation on hold. The 
     copy process on the McDougal and/or McDougal business partner 
     controlled accounts was suspended as well, due to equipment 
     and records relocation.


                     august 1 to september 2, 1992

       The criminal investigator transferred to the Kansas City 
     office at the end of 7/92, resuming the analysis of Madison 
     documents and checks. A criminal referral (#C0004) was 
     subsequently generated alleging a $1.5 million check kiting 
     scheme between the McDougal and/or McDougal business partners 
     controlled entities, including Whitewater. This referral was 
     submitted to the FBI and U.S. Attorney, Eastern District of 
     Arkansas on 9/2/92.


                    september 3 to december 15, 1992

       Having submitted the initial referral on MGSL, the criminal 
     investigator redirected priorities to the ongoing 
     investigations of three other failed thrifts, which were 
     intensifying. First Federal Savings, Paragould, Arkansas, 
     which was reaching suspect plea negotiations, First America 
     Savings, Ft. Smith, Arkansas, which had been referred from 
     jurisdiction in the Western District of Arkansas to the 
     Dallas Fraud Task Force, and Cimmaron Federal Savings, 
     Muskogee, Oklahoma, for which investigations had received an 
     allegation of potential fraud from the managing agent. 
     Throughout these investigations, the criminal investigator 
     continued to request and monitor a response on MSGL referral 
     #C0004.


                  december 15, 1992, to March 14, 1993

       The U.S. Attorney's office did not offer any standard 
     response to the MGSL referral, advising either that a case 
     would be opened or that prosecution would be declined, for 
     three months. In response to numerous calls from the criminal 
     investigator during that time, the Little Rock FBI Special 
     Agent in Charge sent a letter of acknowledgement to the RTC 
     stating that both the FBI and U.S. Attorney had received the 
     referral and exhibits. The investigator continued to work on 
     the aforementioned institutions while continuing to monitor a 
     potential response on the MGSL referral.


                        march 15 to may 4, 1993

       The criminal investigator initiated a preliminary review of 
     criminal activity at Savers Savings, Little Rock, Arkansas, 
     out of which a former borrower had been convicted and 
     sentenced in conjunction with a failed Texas S&L. This review 
     involved extensive interviews with the borrower, and a review 
     of his personal and corporate records prior to his 
     sentencing and incarceration in late 4/93. The 
     investigator continued to make verbal requests for a 
     written response from the FBI or U.S. Attorney on MGSL 
     referral C0004.


                           may 4 to 25, 1993

       On 5/4/93, the criminal investigator sent a letter to the 
     U.S. Attorney inquiring about the status of the referral. The 
     response from the U.S. Attorney referred the investigator to 
     the U.S. Justice Department in Washington D.C. The criminal 
     investigator initiated a series of calls to DOJ/Washington to 
     ascertain the status of the referral. Simultaneously, the 
     criminal investigator, criminal investigations department 
     head and the field investigations officer determined that the 
     most expedient way to complete the investigation of 
     previously defined criminal allegations at MGSL was to 
     supplement the investigative manpower.


                         may 31 to june 4, 1993

       Three additional criminal investigators were assigned the 
     task of reviewing loan transactions, checking accounts and 
     subsidiary lending transactions to ascertain the level of 
     criminal activity at both MGSL and MFC. The lead 
     investigator, along with another task assigned investigator, 
     returned to the Little Rock warehouse for further document 
     review. The investigators additionally travelled to four 
     other counties to review land records pertaining to property 
     sales, loan and mortgages reflected in the County Clerk's 
     offices. Those findings were shared with the other assigned 
     investigators.


                       june 5 to october 8, 1993

       The four investigators reviewed and analyzed all available 
     MGSL transactional information for the ensuing 120 days. As a 
     result, nine additional criminal referrals involving multiple 
     MGSL and MFC transactions were generated and submitted to the 
     U.S. Attorney and FBI on 10/8/93.


                            october 17, 1993

       The lead criminal investigator received a letter from the 
     new U.S. Attorney for the Eastern District of Arkansas, Paula 
     J. Casey. The letter stated that referral #C0004, submitted 
     9/2/92, had been declined due to ``insufficient 
     information''.


                  november 1, 1993 to January 24, 1994

       RTC Criminal investigations continues to support the 
     investigative efforts of the FBI and U.S. Attorney by 
     providing MGSL and MFC documents warehoused in Kansas City, 
     and offering assistance with ongoing subpoena compliance.
       The responsibility for investigation of all failed Arkansas 
     thrifts was assumed by the Tulsa RTC Office of Investigations 
     during the first quarter of 1991. Responsibility was assumed 
     from the Eagan/Minneapolis RTC Office of Investigations; the 
     lead Eagan investigator for Madison Guaranty Savings, Little 
     Rock, Arkansas at that time was Mike Hammerly.
       When the Tulsa office assumed this responsibility, Madison 
     Guaranty was assigned to civil Investigator Wyatt Adams. 
     Shortly after the reassignment of the Arkansas thrifts, 
     several members of the Tulsa Office of Investigations made a 
     sweep through the failed Arkansas shops and appropriated all 
     the records deemed necessary for the effective completion of 
     both civil and criminal investigations.
       In mid summer 1991, Investigator Wyatt Adams traveled to 
     Little Rock to review Madison Guaranty records held by the 
     acquiring entity, Central Bank and Trust, in an old, non-
     climate controlled building downtown on the river, which had 
     been converted to a ``records storage'' facility. According 
     to Adams, when he arrived there were extensive records in 
     poor condition, haphazardly heaped into the storage space on 
     the second floor, which was poorly lit and protected by a 
     chain link fence and a padlock. Boxes were on their sides 
     with records dumped out, DDA binders were poorly stacked in 
     one corner, and multiple boxes had been shoved into shelving, 
     with no identifiable inventory. It should be noted that these 
     records were already in the warehouse at the time of the 
     Investigations team Spring 1991 ``sweep'' through the 
     Arkansas thrifts, and that the former Managing Agent concurs 
     that, to his knowledge, there was no inventory of these 
     records.
       In July 1991, the criminal investigation of Madison 
     Guaranty was assigned to Investigator Jean Lewis. A follow-up 
     criminal investigation was tentatively slated to begin during 
     the third quarter of 1992, due to the fact that former thrift 
     owner James B. McDougal had previously been tried on Bank 
     Fraud charges stemming from Madison Guaranty, and was 
     acquitted in 1990. The follow-up investigation was intended 
     to ensure that any remaining potential criminal matters had 
     been properly reviewed and addressed.
       In March 1992, Senior Investigator Specialist Jon Walker 
     contacted the Kansas City regional RTC office regarding an 
     article that has appeared in the New York Times stating 
     possible ties between Whitewater Development, Madison 
     Guaranty Savings and Loan, and Bill & Hillary Clinton. 
     Personnel in the KC regional office then contacted the Tulsa 
     office with a request that this issue be reviewed to 
     determine if Investigations was aware of, had reviewed and/or 
     appropriately addressed matters pertaining to the possible 
     relationship between Whitewater Development and Madison 
     Guaranty.
       After a review of all available Tulsa Investigations 
     inventory documents, Investigators Adams and Lewis were 
     detailed to the warehouse in Little Rock to review the 
     remaining Madison records and ensure that nothing had been 
     overlooked with regard to any potential action on this 
     matter. Investigator Lewis noted, with concurrence from 
     Adams, that upon arrival that the records were in very poor 
     condition, appeared to have been dumped and/or crammed into 
     the warehouse space, and that there was no available 
     inventory provided by Central Bank & Trust personnel which 
     could identify the nature of these records. Investigator 
     Adams noted that this was the same condition in which he'd 
     found the records in 1991. Boxes had to be rearranged in 
     order to establish work space and room for a table and two 
     chairs.
       During the review of these records, neither Investigator 
     Adams or Lewis located any loan files and loan records 
     relating specifically to Whitewater Development or the 
     Clintons. Investigator Adams then went through a number of 
     Demand Deposit Account binders, to ascertain if Whitewater 
     had maintained a checking account at Madison Guaranty. He 
     located an account and statements for 1984, 1985 and 1986. 
     Investigator Lewis reviewed multiple boxes of records, and 
     recovered several documents from former thrift officer files 
     that warranted further review. Among those documents was a 
     ledger sheet marked ``Reserve for Development--Maple Creek 
     Farms'' from the records of former Madison CFO Greg Young. On 
     that ledger sheet was noted a $30,000 development reserve 
     cost for an engineering survey charged to Whitewater 
     Development. There was also a limited amount of microfilm 
     located at the warehouse, which was appropriated under the 
     terms of the P&A Agreement and returned to Tulsa along 
     with several DDA binders, with permission from Central 
     Bank & Trust. A signed receipt containing an itemized list 
     of the documents taken by Investigators Adams and Lewis 
     was left with * * * of CB&T.
       Prior to departing Little Rock, Investigators Adams and 
     Lewis reviewed the Madison daily work film held by Central 
     Bank & Trust to research the flow of funds through the 
     Whitewater account as pulled from the monthly statements, 
     which is a standard operating procedure for Investigations. 
     Several checks payable to the Bank of Cherry Valley which 
     identified loan numbers, were identified and copied from the 
     daily work. Also copied were numerous checks payable to 
     entities entitled Pembroke Manor, Rolling Manor, Madison 
     Marketing and others, all of which were signed by James or 
     Susan McDougal, payable to Whitewater Development and 
     contained the notation ``loan'' in the memo filed on the 
     check. Accounts were located and reviewed for these other 
     identified entities; similar checks containing the ``loan'' 
     notation were found to have been paid between the entities. 
     At that time, both investigators concurred that additional 
     research would be appropriate, and requested all available 
     film relating to Madison Guaranty and returned it to Tulsa, 
     leaving a receipt for the film, binders and original 
     documents pulled from former office files with CB&T employee 
     Bonnie Crocheron. Copies of the entity statements and checks 
     were pulled and/or duplicated from film for the years 1984, 
     1985 and 1986. * * *
       After the original film was duplicated, the duplicates were 
     returned to Central Bank & Trust for their retention, and the 
     original film was retained in Tulsa by an RTC research 
     contractor. The criminal investigation of Madison then 
     continued, as the civil claims had previously been closed out 
     by PLS.
       In conjunction with the ongoing Madison investigation, 
     Kansas City Investigators Jean Lewis and Randy Knight 
     traveled to Little Rock in 5/93 to revisit the Madison 
     records held in the downtown warehouse. Upon arrival 
     Investigator Lewis immediately noted the condition of the 
     records was significantly more organized than it had been 
     during the previous visit, and it was evident that a number 
     of boxes had been cleared out.
       During this visit to the warehouse, Investigator Lewis 
     learned from the storage facility attendant that the law firm 
     of Mitchell, Selig, Jackson, Tucker & White, former general 
     counsel to Madison Guaranty Savings, also stored records at 
     the warehouse.
       A number of the remaining boxes were reviewed, and the keys 
     returned to * * * at Central Bank & Trust. At that time, 
     Investigator Lewis noted to * * * that the warehouse seemed 
     to lack a number of boxes that had previously been there, and 
     * * * advised that some of the records had been retrieved and 
     were being held in a back room at the bank (CB&T). When asked 
     why this had not been disclosed when the keys had been picked 
     up rather than returned, Ms. Crocheron's response was ``you 
     didn't ask.''
       It should be noted that, according to the US Attorney's 
     staff in Little Rock, * * * to Madison and was summoned 
     before the Grand Jury for testimony. The outcome of that 
     investigation has never been disclosed to this office.
       In conjunction with the ongoing FBI investigation of the 
     RTC's referrals, Investigations advised the FBI that 
     additional original Madison Guaranty microfilm, along with 
     the records at the warehouse, were under the control of 
     Central Bank & Trust. It is the understanding of Kansas City 
     Office of Investigations that the aforementioned records have 
     now been subpoenaed by the U.S. Attorney's office and are now 
     under the control of the Little Rock FBI. The original 
     Madison film held by Investigators has also been turned over 
     to the FBI along with other records subject to Grand Jury 
     Subpoena.
                                  ____



                                 Resolution Trust Corporation,

                               Kansas City, MO, September 1, 1992.
     Ms. Steve Irons,
     Supervisory Special Agent, White Collar Crime Unit, Federal 
         Bureau of Investigation, Two Financial Centre, Suite 200, 
         Little Rock, AR.
     Re: No. 7236 Madison Guaranty Savings & Loan, Little Rock, 
         Arkansas--In Receivership (11/29/90), Criminal Referral 
         Number C0004.

       Dear Sir: Certain matters have come to our attention which 
     may constitute criminal offenses under Federal law. Enclosed 
     is a report of an Apparent Criminal Irregularity.
       Information in this referral may have been derived from 
     financial records of customers of federally insured financial 
     institutions. I hereby certify that (A) there is reason to 
     believe that these records may be relevant to a violation of 
     Federal criminal law, and (B) the records were obtained in 
     the exercise of the RTC's supervisory or regulatory 
     functions.
       Due to the extensive nature of the exhibits relating to 
     this referral, they are being submitted to the U.S. 
     Attorney's office under separate cover at a later date.
       Please direct any inquiries to the Investigator identified 
     on the referral form, or to Lee O. Ausen, Department Head/
     Criminal Investigations, Kansas City Consolidated Office.
           Sincerely,
                                                 L. Richard Iorio,
                                      Field Investigation Officer.
       Enclosure.
                                  ____



                                 Resolution Trust Corporation,

                               Kansas City, MO, September 1, 1992.
     Hon. Charles A. Banks,
     U.S. Attorney, Eastern District of Arkansas, U.S. Post Office 
         and Courts Building, Little Rock, AR.
     Re: No. 7236 Madison Guaranty Savings & Loan, Little Rock, 
         Arkansas--In Receivership (11/29/90), Criminal referral 
         Number C0004.

       Dear Sir: Certain matters have come to our attention which 
     may constitute criminal offenses under Federal law. Enclosed 
     is a report of an Apparent Criminal Irregularity.
       Information in this referral may have been derived from 
     financial records of customers of federally insured financial 
     institutions. I hereby certify that (A) there is reason to 
     believe that these records may be relevant to a violation of 
     Federal criminal law, and (B) the records were obtained in 
     the exercise of the RTCs supervisory or regulatory functions.
       Due to the extensive nature of the exhibits relating to 
     this referral, they are being sent to your office under 
     separate cover.
       Please direct any inquiries to the Investigator identified 
     on the referral form, or to Lee O. Ausen, Department Head/
     Criminal Investigations, Kansas City Consolidated Office.
           Sincerely,
                                                 L. Richard Iorio,
                                     Field Investigations Officer.
       Enclosure.
                                  ____



                               memorandum

     To: Criminal Admin File.
     From: Jean Lewis, Criminal Investigator.
     Date: May 3, 1993.
     Re: Background remarks and conversation with AUSA Bob 
         Roddey's office re: Madison Guaranty Savings referral.

       In March 1993, shortly after the departure of former U.S. 
     Attorney Chuck Banks, I was advised by AUSA Bob Roddey on an 
     unofficial basis, that Banks had forwarded the ``Madison 
     referral'' to Justice in Washington D.C. almost immediately 
     after receiving it last September; Roddey also added that 
     Banks had taken this action as the referral was ``politically 
     hot''.
       I contracted Roddey's office early this afternoon to see if 
     AUSA Floyd Mac Dodson was still with the U.S. Attorney's 
     office, or if he had left with Chuck Banks. I was advised by 
     Roddey's secretary, Laura, that Dodson did, in fact, leave 
     with Chuck Banks, and she offered me their number, which I 
     declined. I asked her what would have happened to Dodson's 
     cases, and she offered to ``check the computer'' and call me 
     back, if I could give her a specific case, which I did, 
     identifying Madison Guaranty Savings criminal referral 
     #C0004.
       Approximately five minutes later, Laura called back and 
     advised me that no record of that referral showed up in their 
     computer system; she then advised me that in conversing with 
     AUSA Roddey, he told her that Banks had sent it to Justice in 
     Washington, and that ``we'd probably never hear about it 
     again''.
       A letter inquiring about the status of the referral has 
     been prepared to send to U.S.A. Pence later today.
     Richard Iorio
     Lee Ausen.
                                  ____



                               memorandum

     To: Criminal Admin. File.
     From: Jean Lewis.
     Date: May 19, 1993.
     Re: Additional conversation with Office of Legal Counsel for 
         U.S. Attorney's, U.S. Justice Department, Washington, 
         D.C.

       In following up my previous discussion with the Office of 
     Legal Counsel on May 13, I contacted Dyone Mitchell 
     (secretary) of that office to see if she had been able to 
     determine the status of the Madison referral, as I had not 
     heard back from her. She consulted her notes and advised me 
     that they ``have no record of that referral, it is not in 
     their computer system, it has not been given to an 
     attorney''; upon repeating this response to her, she 
     reiterated ``no ma'am, that referral has not been submitted 
     to this office.''
       After advising Lee Ausen and Richard Iorio of this 
     conversation, the decision was made to resubmit the referral 
     through the U.S. Attorney's office in Little Rock, and 
     contact Ms. Mitchell in the Office of Legal Counsel to see if 
     that office should be copied on the referral and letter to 
     Richard Pence, U.S. Attorney in Little Rock. I contacted Ms. 
     Mitchell again to inquire as to whether that office should be 
     copied on the referral. She said yes, and when I asked to 
     whose attention it should be directed, she responded that it 
     should be sent to Acting Assistant Attorney General Daniel 
     Koffsky, as the Assistant Attorney General, Mr. Dellinger, 
     has not yet been confirmed.
       The letter of re-submission will be prepared this 
     afternoon, with a copy going to Mr. Koffsky's attention.
                                  ____

     To: L. Richard Iorio and Lee O. Ausen.
     From: L. Jean Lewis.
     Subject: No. 7236/Madison Guaranty Savings.
     Date: Wednesday, May 19, 1993.

       In following up on the suggestion that Mr. Daniel Koffsky, 
     Acting Assistant Attorney General, be sent a copy of Madison 
     referral No. C0004, I contacted the Office of Legal Counsel 
     to verify the correct address. In speaking with Dyone 
     Mitchell of that office, I reiterated the address provided by 
     US Atty Richard Pence, which reads: Office of Legal Counsel, 
     Executive Office for U.S. Attorneys, U.S. Justice Department, 
     Washington, DC 20530.
       The letter provided the phone number (202) 514-2041.
       Ms. Mitchell advised that the Office of Legal Counsel and 
     the Executive Office for the U.S. Attorney's were two 
     separate sections, and that the referral may have been 
     forwarded to the Executive Office instead of legal Counsel. 
     She then connected me with the operator, who put me through 
     to the Executive Office where I spoke with Stephanie Kennedy. 
     I explained to Ms. Kennedy what I was looking for, and she 
     said she would get back to me this afternoon.
       She called me back at 3:30, and advised that she had 
     forwarded the matter on to Donna Henneman in ``Legal 
     Counsel'', who would check it out and call me back tomorrow. 
     I then contacted Ms. Henneman to offer background information 
     on what I was looking for. When I explained that it was a 
     referral out of Madison Guaranty, forwarded to that office by 
     Chuck Banks, she had immediate knowledge, stating ``oh, the 
     one involving the President and his wife''. She then stated 
     that the referral had been sent to that office (exactly which 
     office is till unclear to me) as a special report for the 
     attention of the Attorney General, and not as a referral for 
     prosecution. She then stated that ``anytime a referral comes 
     in that would make the department look bad, or has political 
     ramifications, it goes to the Attorney General.'' She further 
     added that the referral had been submitted to that office 
     ``because of the political ramifications and political 
     motivations'', and then told me that referrals were not 
     prosecuted out of that office. She then stated that the 
     referral had been declined. I advised her that the referral 
     had not been declined, and read her the letter sent to this 
     office by U.S. Attorney Richard Pence. She acknowledged that 
     she was confused, and told me she would speak with her 
     supervisor, Deborah Westbrook, and have her call me back 
     tomorrow. I then asked for Ms. Henneman's title, and she 
     informed me that she was the Ethics Program Manager. I 
     thanked her and ended the conversation.
       I'll keep you posted if and when I hear from Ms. Westbrook.
                                  ____

     To: L. Richard Iorio and Lee O. Ausen.
     From: L. Jean Lewis Investigations
     Subject: No. 7236/Madison Guaranty.
     Date: Wednesday, May 26, 1993.

       I've just received a follow-up call from Donna Henneman at 
     Justice in D.C. She informed me that after speaking with 
     Deputy Director/EO Wayne Rich she learned that referral 
     #C0004 had been sent to former Special Counsel Ira Raphelson. 
     I noted that Mr. Raphelson is now in private practice, she 
     concurred and said that she wasn't sure where it had gone 
     after he left, but that she was going to call the ``criminal 
     fraud division at Justice'' and see if they are prosecuting 
     the case or if a declination letter has been issued. I 
     restated that, to my knowledge, the referral had not been 
     declined, and that I had been advised by an FBI agent in 
     Little Rock that it was a ``very solid case of check kiting, 
     and was highly prosecutable.''
       I then identified the suspects named in the referral for 
     her reference, and she thanked me and told me she'd be back 
     in touch as soon as she found something. She also stated that 
     she was growing increasingly frustrated with the situation, 
     because she had seen the information, knew that it had come 
     in, and couldn't understand why she was having such a hard 
     time tracking where the referral and exhibits had gone.
       To date, each time she has given me a date that she would 
     call back, she has kept her word. I'll let you know when I 
     hear from her again.
                                  ____

     To: L. Richard Iorio Investigations.
     From: L. Jean Lewis Investigations.
     Date: Tuesday, June 8, 1993.

       As we discussed this morning, I was going to contact Audrey 
     Word at DOJ in Washington this afternoon; however, before I 
     could call, Donna Henneman in the Executive Office for U.S. 
     Attorneys called me. It seems that Madison referral #C0004 
     has reappeared on her desk. Audrey Word was successful in 
     locating the referral within the Fraud section of the 
     Criminal Division and determined that the individual assigned 
     to the referral ``didn't want to deal with it'', so she sent 
     the referral and all pertinent info back to Donna Henneman 
     for further disposition.
       Donna advised me that the Criminal Division (no one 
     specifically identified) sent a memo to Doug Frazier, 
     Associate Deputy Attorney General (in Deputy Atty General 
     Heyman's office) advising him that there was ``no 
     identifiable basis for recusal of the U.S. Attorney in the 
     Eastern District of Arkansas''; this was a direct quote from 
     the memo, as she read it. She then told me that she'd 
     contacted Mr. Frazier who did not remember receiving the 
     memo, and suggested that she get the memo and the referral to 
     him for review and a final decision.
       She has subsequently sent him both the referral and the 
     memo, and said she'll keep me posted. I then advised her that 
     during the intervening period, additional information has 
     surfaced that would further support the allegations contained 
     in the referral, so I would be most curious as to their 
     decision. I then concluded the conversation by telling her 
     ``whatever the decision is, I need something in writing so 
     that I can close out the file with a declination, or offer 
     support for an ongoing case.'' She agreed and said she'd stay 
     in touch.
       I'll keep you posted.
                                  ____

     To: L. Richard Iorio Investigations.
     From: J. Jean Lewis Investigations.
     Date: Wednesday, June 23, 1993.

       At approximately 3:00 this afternoon, I spoke with Donna 
     Henneman in the Executive Office for U.S. Attorneys, 
     regarding the status of the Madison referral #C0004. She 
     advised that she had sent the ``package'' to Associate Deputy 
     Attorney General Doug Frazier on June 8, as we had previously 
     discussed, but that she had received the entire package back 
     on her desk today with no further answers, as Mr. Frazier was 
     now the new U.S. Attorney in one of the Florida districts; 
     she had not determined whether Mr. Frazier had taken any 
     action prior to his departure, and had spoken with her 
     supervisor regarding her next action shortly before I 
     contacted her. She advised that she will attempt to contact 
     Mr. Frazier in Florida sometime tomorrow, and determine what 
     decision, if any, had been made.
       She then advised that ``this sort of thing happens all the 
     time when we're trying to get the guys upstairs to make a 
     decision.'' She said she'd be back in touch as soon as she 
     had an answer from Doug Frazier, or his replacement, a Mr. 
     Dave Margolis.
       This was the 8th conversation I've had with Ms. Henneman 
     since I first contacted her on May 19, 1993.
       I'll keep you posted.
                                  ____

     To: L. Richard Iorio Investigations.
     From: J. Jean Lewis Investigations.
     Date: Wednesday, June 23, 1993.

       Donna Henneman (EO/US Attorneys) just called me back to let 
     me know she'd spoke with former Associate Deputy Attorney 
     General Doug Frazier. He advised her that he met with Tony 
     Muscato, the Director of the Executive Office for U.S. 
     Attorney's, and that the decision has been made to return the 
     referral to the U.S. Attorney in the Eastern District of 
     Little Rock, as there was ``no basis for the recusal of the 
     U.S. Attorney'', and apparently a lack of ``conflict of 
     interest.''
       Ms. Henneman then added that she doubted whether or not the 
     U.S. Attorney, Eastern District/Arkansas would be aware of 
     this situation yet, but suggested that I wait a few days and 
     then contact that office in Little Rock.
       She asked to be kept posted on the outcome, and offered her 
     continued assistance whenever and however possible.
                                  ____

     To: L. Richard Iorio Investigations.
     From: L. Jean Lewis Investigations.
     Date: Tuesday, June 29, 1993.

       I received a call this afternoon from a highly reliable and 
     confidential source, that the Madison referral (C0004) has 
     been returned to the U.S. Attorney's office in Little Rock, 
     Arkansas. My source has advised me that the acting U.S. 
     Attorney, Richard Pence, has stated he has no intention of 
     acting on this referral, and plans to let it sit until such 
     time as the new U.S. Attorney designee Paula Casey, takes 
     office on either an interim or permanent basis. It was stated 
     that there was displeasure at the fact that the referral had 
     been returned to the Little Rock office, and that the reason 
     cited for its' return was that the Executive Office for U.S. 
     Attorney's found no basis for recusal, and no conflict of 
     interest emanating from the U.S. Attorney's office in the 
     Eastern District. However, the acting U.S. Attorney is of the 
     opinion that if the (strong) case against James McDougal is 
     taken to trial, it will appear to the ``sour grapes'' due to 
     his acquittal during his first bank fraud trial.
       I was further advised that there is no definite date yet as 
     to when Ms. Casey's confirmation will occur, and that is 
     likely that she will assume her responsibilities on an 
     interim basis. My source has advised that I will get a 
     ``head's up'' call when Ms. Casey assumes her new 
     responsibilities, but that such appointments have been 
     delayed in the past, and may take a while.
       I'll keep you advised should I hear anything further.
                                  ____

     To: L. Richard Iorio Investigations.
     From: L. Jean Lewis Investigations.
     Date: Thursday, September 23, 1993.

       I've just had a conversation with Donna Henneman, Ethics 
     Program Manager, Executive Office for U.S. Attorneys. I 
     called Donna to make a final determination as to whether or 
     not she wants formal notification of the existence of the 
     subsequent referrals being submitted to the U.S. Attorney, 
     Eastern District of Little Rock, on Madison.
       In discussing the standard RTC procedure of the submission 
     of referrals, she has requested that she be copied on the 
     transmittal letters that go to the U.S. Attorney and FBI. At 
     the time she receives the copies of those letters, she will 
     then request the referrals and exhibits from the U.S. 
     Attorney's office for any necessary follow up. So, at her 
     request, I'll ask Donna Minton to cc: Ms. Henneman in her 
     official capacity. She felt that a letter requesting copies 
     at this point was unnecessary, and if it becomes necessary, 
     she will go through her channels at Justice to obtain the 
     documentation from U.S. Attorney Paula Casey. Donna has also 
     requested that I provide a brief one paragraph summary of the 
     content of the referrals with the transmittal letters, so 
     that she will be aware of those with ``sensitivity issues.'' 
     I will be glad to provide the requested summary as an 
     addendum paragraph to the bottom of each transmittal letter.
       She then asked me about the final disposition of MGS&L 
     referral C0004. I told her that I had been advised that it 
     was received back in the U.S. Attorney's office, but that I 
     had received no formal notification that a case had been 
     opened, nor a declination letter. I expressed my concerns 
     that the same situation could befall the next referrals to be 
     submitted, and she assured me that she and her supervisor, 
     Deb Westbrook, would stay closely in touch with the 
     situation, due its potentially political ramifications, some 
     of which I explained for her edification.
       She asked me to stay in touch as to the responses that I 
     get from the U.S. Attorney's office, and assured me that, if 
     necessary, the ``higher-ups'' at Justice would make sure 
     something got done with these referrals, including the first 
     one, which in her words ``should have been handled by now, 
     one way or the other.''
       I'll keep you posted.
                                  ____

     To: L. Richard Iorio Investigations.
     From: L. Jean Lewis Investigations.
     Date: Wednesday, September 29, 1993.

       I've just received a call from Donna Henneman, Ethics 
     Program Manager, Executive Office for U.S. Attorney's, 
     Washington, D.C. She advised that she had spoken to her 
     supervisor, Deb Westbrook, and Ms. Westbrooks supervisor, 
     Doug Frazier, regarding whether or not the Executive Office 
     wanted copies of the madison referrals slated for submission 
     this week. Ms. Westbrook and Mr. Frazier have determined that 
     the Executive office should receive copies of the referrals 
     and exhibits. Upon receipt, they will review them and 
     determine whether to instruct the U.S. Attorney's office to 
     act on them accordingly, or if they should be forwarded to 
     the Public Integrity Section of DOJ for further review. In 
     inquired as to the nature of the Public Integrity Section and 
     was advised that it is the section of DOJ responsible for the 
     prosecution of public officials. Ms. Henneman also advised 
     that they have made the decision to get the Deputy Attorney 
     General's office involved in this situation, and bring them 
     up to speed.
       I asked her to submit this request in writing, in order to 
     document the Investigations file and she responded that she 
     would do so, faxing me a letter this afternoon. I've provided 
     her with the fax number and will copy you upon receipt of her 
     letter.
       To briefly summarize the situation to date, I contacted the 
     Executive Office for U.S. Attorney's on May 13, 1993, at the 
     written suggestion of U.S. Attorney Richard Pence, pursuant 
     to his letter of May 10, 1993 regarding my written inquiry as 
     to the final disposition of Madison referral #C0004, 
     submitted on 9/1/92. Mr. Pence advised that the referral had 
     been forwarded to the Executive Office by former U.S. 
     Attorney Charles A. Banks due to what he deemed was a 
     ``conflict of interest''. This information was relayed to Ms. 
     Henneman during my first conversation with her. During 
     subsequent calls I received from Ms. Henneman, she advised me 
     as to her progress in tracking the whereabouts of referral 
     #C0004, which she finally located and had forwarded back to 
     her office on June 8, 1993. At that time, Ms. Henneman 
     advised me that the decision had been made by personnel in 
     the Criminal Division of DOJ that there was ``no identifiable 
     basis for recusal of the U.S. Attorney in the Eastern 
     District of Arkansas'', and that the referral would be 
     forwarded back to the U.S. Attorney's office in Little Rock. 
     Since that time, Ms. Henneman has contacted me to follow up 
     on the final disposition of the referral. I have advised her 
     that this office has not yet received notification of an 
     opened case, or a letter declining prosecution. During these 
     aforementioned conversations, the issue was raised as to 
     further referrals, and whether the Executive Office should be 
     copied on any further referrals to avoid a recurrence of 
     circumstances. I received notification of that decision today 
     when Ms. Henneman contacted me, as previously outlined.
       Please let me know if you have any questions.
                                  ____

     To: L. Richard Iorio Investigations.
     From: L. Jean Lewis Investigations.
     Date: Wednesday, September 29, 1993.

       I've received a follow-up call from Donna Henneman with the 
     Executive Office for U.S. Attorneys. She spoke with her 
     supervisor, Deb Westbrook, regarding my request for a written 
     follow-up to her verbal request that the Executive Office be 
     copied on all the Madison referrals and exhibits. Ms. 
     Westbrook has withdrawn her initial request for copies, and 
     stated that they will go through the U.S. Attorney's office 
     to obtain copies rather than having us copy their office 
     directly. Ms. Henneman indicated that this route would not 
     make the U.S. Attorney's office feel as though the Executive 
     Office was ``going behind their back'' in requesting copies 
     of the referrals.
       She then reiterated that she would like to be copied on the 
     transmittal letters that will be sent with the referrals to 
     the U.S. Attorneys and the FBI, with a brief summary 
     paragraph outlining the suspects and content of each 
     referral. I agreed to her request, and will make arrangements 
     to provide the requested summary on the transmittal letters.
       I'll let you know if I hear from her again.
                                  ____

     To: Lee O. Ausen.
     From: L. Jean Lewis.
     Subject: #7236 Madison Guaranty.
     Date: Tuesday, October 26, 1993.

       Just FYI...
       Based on our conversation this afternoon regarding the 
     OCC's inability to locate their past exams for UNB/Little 
     Rock, I took a shot at a hunch, and made another call to 
     Cristina Flechas, the attorney for the FDIC in Memphis who 
     had previously advised me (in response to my written request 
     of 6/23) that OCC would have been the regulatory agency for 
     UNB during 1986.
       Cristina, so I have learned, is no longer with the FDIC in 
     Memphis. However, I spoke to her successor, Broderick 
     Nichols, and outlined the previous request with him, asking 
     him if he would do some additional followup just on the off 
     chance that the FDIC might have done a concurrent exam on UNB 
     with OCC at some point between 1983 and 1987. I then 
     explained to him that the OCC seemed to be having some 
     difficulty in locating their records, and advised him that I 
     was informed by OCC that prior to 1991, UNB was actually 
     First National Bank of Jacksonville. Well, it turns out that 
     Broderick Nichols is from Little Rock. What a small world! 
     And he evidently grew up knowing where Union National Plaza 
     is and that Union National Bank was, and still is, the 
     largest bank in Little Rock. He was somewhat concerned about 
     the fact that OCC couldn't find their exams, and has offered 
     his expeditious assistance in locating any concurrent exams 
     done by FDIC. He's also offered to aid me in locating other 
     potential leads and sources within OCC that might be able to 
     rediscover the whereabouts of the UNB exams. He couldn't 
     quite understand how the OCC could lose a $500 million bank. 
     Does this sound familiar?
       I'll keep you posted.
                                  ____

     To: L. Richard Iorio.
     From: L. Jean Lewis.
     Subject: #7236 Madison Guaranty.
     Date: Wednesday, October 27, 1993.

       Just got a call from Donna Henneman, Ethics Program 
     Manager, Executive Office for U.S. Attorneys. She asked if 
     I'd received a declination letter on the first referral 
     (C0004) from the U.S. Attorney in Little Rock. I told her 
     that we had not received a declination to date. She then 
     advised that her supervisor, Deb Westbrook, had evidently had 
     a conversation with U.S. Attorney Paula Casey, and that Ms. 
     Casey stated that she would be sending a declination letter 
     to the RTC on that particular referral. No date was given, 
     and Donna did not reference the date of the conversation 
     between Ms. Westbrook and Ms. Casey. I asked Donna if she 
     knew the basis for the declination, and she responded that 
     she did not, and hadn't seen a copy of the letter either. She 
     then suggested that if I do not receive the letter of 
     declination within a fairly short time frame, to please let 
     her know.
       Donna also noted that Ms. Westbrook advised her that USA 
     Casey had stated she would ``deal'' with the other referrals 
     as well.
       I'll keep you posted as to any further calls from Ms. 
     Henneman.
                                  ____

                                           United States Attorney,


                                 Eastern District of Arkansas,

                                Little Rock, AR, October 27, 1993.
     Ms. L. Jean Lewis,
     Criminal Investigator,
     Resolution Trust Corporation,
     Kansas City, MO.
     Re #7236 Madison Guaranty Savings and Loan Criminal Referral 
         Number C0004

       Dear Ms. Lewis: I am writing at the request of the Office 
     of Legal Counsel, Executive Office for U.S. Attorneys of the 
     U.S. Department of Justice to let you know the status of this 
     referral.
       As you know, this referral was reviewed by the Criminal 
     Division of the U.S. Department of Justice at the request of 
     the previous United States Attorney for the Eastern District 
     of Arkansas. The matter was concluded before I began working 
     in this office, and I was unaware that you had not been told 
     until I was contacted by the Office of Legal Counsel. After 
     receiving the call from Legal Counsel I reviewed the 
     referral, and I concur with the opinion of the Department 
     attorneys that there is insufficient information in the 
     referral to sustain many of the allegations made by the 
     investigators or to warrant the initiation of a criminal 
     investigation.
       Although I am declining to take further substantive action 
     on this referral, my decision does not foreclose future 
     prosecutions about the matters covered by the referral or 
     related matters in the event that my office and the FBI are 
     given access to records or information indicating that 
     prosecutable cases can be made.
           Sincerely,
                                                   Paula J. Casey,
                                           United States Attorney.
                                  ____



                                 Resolution Trust Corporation,

                                Kansas City, MO, November 1, 1993.
     Re #7236 Madison Guaranty Savings & Loan Criminal Referral 
         Number C0004

     Hon. Paula J. Casey,
     U.S. Attorney, Eastern District of Arkansas, Little Rock, AR.
       Dear Ms. Casey: I have received your October 27, 1993 
     letter regarding the above captioned thrift and referral. On 
     the basis of comments contained within your letter, I am 
     interpreting that correspondence as a formal declination to 
     prosecute referral #C0004. You stipulated in your letter that 
     this matter was concluded prior to the beginning of your 
     tenure as the United States Attorney for the Eastern District 
     of Arkansas. Prior to the receipt of your letter, RTC 
     Investigations was not advised that the matter had been 
     formally concluded.
       Between September 1, 1992 and today's date, this office has 
     received a total of three letters with regard to the 
     aforementioned referral, including your letter of 
     declination. The other two letters were from FBI/SAC Don 
     Pettus, 12/15/92, acknowledging receipt of the referral, and 
     from Acting United States Attorney Richard Pence, 5/10/93, 
     advising this office that he was unaware of the referral 
     status as it had been forwarded to the Executive Office for 
     United States Attorney's by former United States Attorney 
     Chuck Banks.
       If there were other documents produced that are relative to 
     the conclusion of this matter, I would appreciate receiving 
     the appropriate copies.
       The RTC Kansas City Office of Investigations will continue 
     it's policy of cooperation with both the United States 
     Attorney's office and the FBI on all referral related and 
     investigate matters, making all pertinent records accessible 
     as requested.
       Should you have any further questions, or if this office 
     may be of further assistance, please do not hesitate to 
     contact me at (816) 968-7237, or if I am unavailable, 
     Supervisory Investigator Lee Ausen at (816) 968-7243 or Field 
     Investigations Officer Richard Iorio at (816) 968-7212.
           Very truly yours,
                                                    L. Jean Lewis,
                                     Senior Criminal Investigator.
                                  ____

     To: Jane M. Dankowski.
     From: L. Jean Lewis.
     Subject: Madison Guaranty.
     Date: Wednesday, November 10, 1993.

       Hey you! Just a heads up to let you know that Mike Caron, 
     Senior Criminal Investigator, is now the lead investigator on 
     Madison . . . so anymore faxes you send should come to Mike's 
     attention, and any further communication about Madison should 
     go to him, too. The Powers That Be have decided that I'm 
     better off out of the line of fire (and I ain't arguing), but 
     please let me assure you, that we are leaving you in very 
     capable hands! Got any questions beyond that, ask Lee or 
     Richard.
                                  ____

     To: James R. Dudine.
     From: L. Richard Iorio
     Subject: Madison Guaranty.
     Date: Monday, November 15, 1993.

       On Thursday, November 11, 1993, there was an article that 
     appeared in the Washington Post concerning declination of 
     prosecution on the first Madison referral that was 
     transmitted to the Department of Justice (DOJ) on August 31, 
     1992.
       Contained in the article was information that the referral 
     had been reviewed by DOJ and that a decision had been made 
     early on to decline on this referral and that when Paula 
     Casey US Attorney, Little Rock, Arkansas, in fact issued the 
     declination in October 1993, she was simply bringing this 
     matter to a close.
       The document attached clearly refutes this train of 
     thought. In fact, it appears that no thorough review of the 
     document had been conducted as late as June 23, 1993, some 
     ten months after the referral had been initially transmitted. 
     It was not until September 29, 1993 that this office was 
     advised that the referral would be reviewed.
       This whole issue might not be important, however, for 
     purposes of credibility with regard to the RTC's efforts in 
     this area, this memo and attachment are submitted for factual 
     clarity.
                                  ____

       RTC Criminal Referral #C0004 on Madison Guaranty Savings 
     was completed on August 31, 1992, signed by RTC Kansas City 
     Investigations management on September 1, 1992, and sent via 
     certified mail on September 2, 1992, to Charles A. Banks U.S. 
     Attorney, Eastern District of Arkansas, and SSA Steve Irons, 
     FBI, Little Rock.
       By early November 1992, no standard written response of 
     prosecution or declination had been forthcoming from the U.S. 
     Attorney's office. In mid-November 1992, the lead criminal 
     investigator made the first of a number of verbal requests to 
     both the U.S. Attorney and FBI in Little Rock for some form 
     of written acknowledgement that the referral had been 
     received and reviewed. A written acknowledgement dated 
     December 15, 1992, from FBI SAC Don K. Pettus, was received 
     by the lead criminal investigator on January 4, 1993. This 
     acknowledgement stated that the referral had been received, 
     and that further questions should be directed to AUSA Floyd 
     Mac Dodson, who had also received the referral and exhibits. 
     On January 7, 1993, the lead investigator had a conversation 
     with AUSA Mac Dodson in which he advised that he wasn't sure 
     the referral was still in the U.S. Attorney's office in 
     Little Rock, and that if prosecution occurred, it would 
     probably be through a special attorney sent to Little Rock to 
     handle the situation.
       For four months, there was no further communication or 
     correspondence received by Investigations on this matter. In 
     a May 3, 1993, conversation between Investigations and the 
     U.S. Attorney's office, it was indicated that referral #C0004 
     had been ``sent to Justice in Washington almost as soon as it 
     was received last September''. On May 4, 1993 Investigations 
     sent a written inquiry to Acting U.S. Attorney, Richard M. 
     Pence, requesting the status of the referral. On May 12, 
     1993, Investigations received a letter from Mr. Pence (dated 
     May 10, 1993) stating that former U.S. Attorney Charles Banks 
     had determined that his office had a conflict of interest 
     with conducting an investigation or prosecuting criminal 
     charges relating to referral #C0004, and had sent the 
     referral and exhibits to the Office of Legal Counsel 
     (``OLC''), Executive Office for U.S. Attorney's, U.S. Justice 
     Department, Washington D.C. He stated that any further 
     inquiries as to the status of the referral should be directed 
     to that office, providing a phone number in Washington D.C.
       As suggested by Mr. Pence, the lead investigator called the 
     OLC on May 13, 1993. This initiated a series of 15 phone 
     calls between the OLC and Investigations; 10 taking place 
     between May 13 and June 29, 1993, and five transpiring 
     between September 23 and October 27, 1993. The majority of 
     these calls were incoming to Investigations, and provided 
     information as to the progress being made with regard to 
     locating and determining the status of the referral.
       The June 23, 1993 conversation between Investigations and 
     OLC indicated that the decision had been made to return the 
     referral to the U.S. Attorney in Little Rock as there was 
     ``no basis for recusal of the U.S. Attorney'' and apparent 
     ``lack of conflict of interest.'' During a conversation on 
     September 23, the OLC inquired as to the ``final 
     disposition'' of referral #C0004. They were advised by 
     Investigations that no formal notification had been received 
     of either a declination or intent to prosecute, 
     Investigations then advised OLC that there were additional 
     referrals pending; OLC then requested that Investigations 
     remain in contact with the OLC regarding further 
     communication from the U.S. Attorney in Little Rock.
       On September 29, 1993, the OLC contacted Investigations and 
     advised that 1) the Deputy Attorney General's office had been 
     advised of the situation and 2) that the pending and prior 
     referrals would be reviewed and a decision made as to whether 
     or not they be forwarded to the Public Integrity Section of 
     Justice and reviewed for potential prosecution. A verbal 
     request was then made by OLC that they be copied on the 
     transmittal letters to the U.S. Attorney accompanying the new 
     referrals, and that they be further provided with a summary 
     of each referral.
       The nine new referrals were submitted to the U.S. Attorney 
     and FBI in Little Rock on October 8, 1993. On October 13, 
     1993, the Office of Legal Counsel was provided with copies of 
     the transmittal letters, and the requested summaries on each 
     referral.
       On October 27, 1993, Investigations received a call from 
     OLC inquiring as to whether or not Investigations had 
     received a declination letter on referral #C0004; the 
     response was ``no.'' Investigations was advised that U.S. 
     Attorney Paula Casey had advised the OLC that she would be 
     sending a letter of declination to RTC Investigations.
       On November 1, 1993, Investigations received a letter dated 
     October 27, 1993, from U.S. Attorney Paula Casey stating that 
     the disposition of referral #C0004 had been concluded prior 
     to her taking office, and that she ``concurred with the 
     opinion of the Department attorneys that there is 
     insufficient information . . . in the referral to warrant the 
     initiation of a criminal investigation.''
       On November 11, 1993, RTC Investigations learned through an 
     article in the Washington Post, that Paula Casey had recused 
     herself and her staff from any further dealing with the 
     Madison referrals.
                                  ____

     To: Lee O. Ausen.
     From: L. Jean Lewis.
     Date: Monday, November 15, 1993.
       A few comments with regard to our conversation this 
     afternoon about the pending meeting with Donald Mackay and 
     his staff on 11/22.
       You know, Richard knows, Donohue knows, Mike knows, and I 
     know that Mackay is not coming here to look at records. Cut 
     to the bottom line. He is coming here because he wants to be 
     convinced that there either IS or IS NOT a very good case 
     behind those referrals. He isn't coming specifically to 
     discuss subpoena compliance, because he hasn't opened any 
     cases yet. He's coming here to evaluate us, our work, and to 
     try and decide just how good this case is, and how he can 
     best deal with a very sensitive political situation. What 
     would be easiest for him is to decide that, after meeting 
     with RTC Investigations, he can conclude that there is no 
     merit, and has accordingly advised Investigations that the 
     matter will be dropped. If we don't convince him that those 
     referrals are exceptionally solid, well prepared and 
     supportable cases, then there is very little doubt that he 
     will dispense with this situation in very short order.
       Regardless of stated agenda, and regardless of whether or 
     not I'm in attendance, he's going to try and make an 
     objective assessment based on what is presented to him during 
     the meeting. If that's the way the meeting starts out, then 
     you better pull out all the stops to support the work we've 
     done, or that's the last we'll hear of the Madison 
     investigation. That's my instinct talking, and so far, it's 
     been pretty much on target.
       Michael is extremely knowledgable about Madison, and very 
     capable of handling the situation. I would not do him the 
     injustice of thinking otherwise. But internal political crap 
     notwithstanding, if this meeting is going to turn into a 
     turkey shoot, then you are going to need every loaded gun 
     you've got to assist you in convincing this special 
     prosecutor that the case is as good as it looks on the 
     surface. And yes, we have strong documentation to support the 
     allegations. But what's beneath the surface, including where 
     we looked and why, who's tied to who, who's in business with 
     who, who got paid for what and where all the internal and 
     external ties are, isn't in writing. It's in my head.
       I've had my say. The decision is up to you and Richard.
                                  ____



                                 Resolution Trust Corporation,

                               Kansas City, MO, December 21, 1993.
     Mr. Bill C. Houston,
     Regional Director, Division of Supervision, Federal Deposit 
         Insurance Corporation, 5100 Poplar Avenue, Suite 1900, 
         Memphis, TN.
       Dear Mr. Houston: The Resolution Trust Corporation's 
     (``RTC'') Kansas City Office of Investigations is currently 
     conducting an investigation into matters relating to an 
     insolvent Little Rock, Arkansas savings & loan. Significant 
     evidence points to the possibilities of loan ``parking'', 
     loan ``swapping'', insider abuse and collaboration between 
     specific borrowers and the principals of the Bank * * * 
     financial institutions in * * * and Little Rock, Arkansas 
     including the aforementioned insolvent thrift. In order to 
     expedite this investigation, I would appreciate your 
     assistance in providing this office with copies of the 
     Reports of Examination (``ROE'') from 1983 through the most 
     recent exam for the above captioned institutions.
       This written request is made pursuant to the terms of the 
     Agreement Regarding Confidential Information between the FDIC 
     and RTC, as signed by FDIC General Counsel Alfred J. Byrne 
     and RTC General Counsel Gerald L. Jacobs, effective January 
     1, 1992.
       Should you have any questions or require additional 
     information, please do not hesitate to contact me at (816) 
     968-7191. Your expedited attention to this matter is 
     appreciated.
           Very truly yours,

                                             Michael E. Caron,

                                     Senior Criminal Investigator,
                                         Office of Investigations.
                                  ____

     To: Jane M. Jankowski, L. Richard Iorio, Lee O. Ausen, 
         Michael X. Caron.
     From: L. Jean Lewis.
     Date: Thursday, January 6, 1994.

       This is just to advise that earlier this evening, I 
     received a call from * * *  who started out her call with 
     I've been lied to by the Justice Department''. I advised her 
     that I could not offer any comment, but that I would listen 
     to what she had to say.
       She stated that her sources from DOJ, who were there during 
     the end of the Bush Administration, had advised her that the 
     original RTC referral was taken much more seriously than the 
     public has been led to believe, and that while they believed 
     that the Clintons definitely stood to benefit from the 
     alleged check kiting activities, they may not have had 
     serious criminal culpability. They also advised her that the 
     referral was left in Little Rock to prosecute by former USA 
     Chuck Banks, because for Washington to be involved would look 
     ``too political.'' She said that they (her four DOJ sources) 
     all told her that there was no basis for recusal, and no 
     conflict of interest in Little Rock.
       She then advised that Justice sources today informed her 
     that it was line staff attorneys in the Criminal section of 
     DOJ/DC that decided the referral warranted no further 
     investigation, and instructed Paula Casey to decline.
       She also noted that her previous DOJ sources had said that 
     after the Clinton administration came into Washington, there 
     were roadblocks put up around this referral, and that it had 
     been their opinion that the RTC staff was attempting to do a 
     legitimate job, but was being stymied by personnel at Justice 
     for some reason. She asked me if it was true that the 
     Clintons were named as witnesses on the referral; I declined 
     comment. She asked me if it was true that the RTC had not 
     been notified for months after the referral was allegedly 
     declined by the staff attorneys in DC; I declined comment.
       I told her that she would have to call you (Jane) in Public 
     Affairs for any additional information, and she advised me 
     that she'd already talked to you, and got no information. She 
     stated that she understood that I was in a difficult 
     position, for which I thanked her, and the conversation 
     ended.
       I found what she had to say very interesting. In the 
     future, I'll comply with Richard and Lee's wishes that I not 
     even listen to what a reporter has to say, and just offer a 
     no comment. However, when someone starts out with ``I've been 
     lied to by the Justice Department'', it's human nature to 
     wonder whether or not it is true.
       Thus endeth the lesson.
       This document is a recap of a phone call that I just 
     received from * * * , reporter * * * whose opening comment 
     was ``I've just been lied to by the Justice Department.'' My 
     comment was that I would not be able to respond to any of her 
     questions, but that I was fascinated by the fact that she 
     thought she'd been lied to, so I would listen to what she had 
     to say.
       She outlined her credentials, stating that she'd written a 
     book on drug trafficking, and had covered the ``peanut 
     loans'', Bert Lance, Billy Carter, Jimmy Carter and the major 
     governmental agencies during the Carter administration.
       She'd been advised that I was the investigator on the case, 
     and wanted to know which of the stories she'd been told by 
     her sources at Justice were correct. Evidently, she had four 
     former Justice sources who were there during the Bush 
     administration, and that had been there when Chuck Banks sent 
     the referral to Washington. The story they told her was as 
     follows:
       The referral was originally sent to DC as an ``urgent 
     report'' for the Attorney General's review, due in part to 
     the political sensitivity of some of the identified names, 
     stating that Banks felt his office had a conflict of 
     interest. (This coincides with what my letter from Richard 
     Pence states, and what Donna Henneman told me during our many 
     conversations on the whereabouts of the referral). There are 
     conflicting stories about why Keeney wrote the memo 
     referenced in the Schmidt/Isikoff story of 1/5; her sources 
     stated that when the RTC referral was reviewed at Justice, it 
     was taken much more seriously than the public has been led to 
     believe, and that they believed that the Clinton's stood to 
     benefit from the check kite although they may not have had 
     serious criminal culpability. She asked if it was true that 
     the Clinton's were named as witnesses on the referral; I told 
     her no comment.
       She said that her former Justice sources advised her that 
     Banks had never recused himself, and that CID/DOJ DC left the 
     referral in Little Rock and told Banks to prosecute, because 
     1) there was no conflict of interest, 2) there was no basis 
     for recusal, and 3) that for Washington to get involved would 
     ``look too political'' since it was right before and after 
     the '92 election. Her sources also indicated that DOJ now 
     seems to be deliberately making it look like the referral was 
     ``vague'' and ``ambiguous'', and not to be taken seriously.
       She stated that her sources told her that it appeared that 
     the RTC folks were legitimately trying to do their job, and 
     had legitimate concerns relating to the allegations contained 
     in the referral, but that when the Clinton administration 
     came in, somebody started putting up roadblocks on the 
     referral, and her sources didn't know where it was coming 
     from.
       Her current Justice sources state that it was the line 
     staff attorneys in CID/DOJ DC that made the decision several 
     months ago that the referral warranted no further 
     investigation, and instructed Paula Casey to decline 
     accordingly; however, the RTC wasn't notified for months, 
     which should have been corrected.
       * * * went on to ask several questions, all of which I 
     replied I could not answer, and referred her Public Affairs 
     and Jane Jankowski. She stated that she'd already talked to 
     Jane, and that it had gotten her nowhere. She asked if I knew 
     anyone else that she could talk to, or if anyone that had 
     left the RTC would have any information. I stated that there 
     were no names that I could give her other than Jane Jankowski 
     in Public Affairs. She then asked me if it was true that the 
     RTC had not been notified of the referral declination for 
     several months after it had been allegedly declined, and I 
     told her no comment.
       She said that she understood that I was in a difficult 
     position, and but that she needed all the help she could get. 
     I thanked her for understanding the difficultly of my 
     position, advised her that I understood that she was only 
     trying to do her job as a professional, but that I could not 
     professionally or ethically make any comment about the 
     investigation. She offered her phone numbers, which I did not 
     write down. She thanked me for my time, and hung up.
       My overall impression of this conversation was that she is 
     very close to the heart of this story, and that she is almost 
     on top of the ``white paper'' chronology outlining the 
     sequence of events and communication between DOJ and RTC on 
     C0004.
       Lee Ausen was present for the entire conversation that I 
     had with * * *, and suggested to me shortly before the 
     conversation ended that I terminate the call with a ``time 
     out'' gesture. He and Richard Iorio both advised that if she 
     included anything in her story regarding that fact that I'd 
     even listened to what she had to say, it would look bad for 
     the RTC, and recommended that in the future, I not even 
     listen to what a reporter has to say.
       I advised them both that I felt that listening to what * * 
     * had to say provided valuable information, and that there 
     was no point in being rude to the press, anymore than there 
     was any point in being rude to Justice or the FBI. ``No 
     comment'' does not have to be offensive. I further stated 
     that I would never do anything to undermine that efforts that 
     the RTC has made, or take any action that would question our 
     credibility or integrity, let alone do anything to compromise 
     the investigation on which I have spent the past two years as 
     the lead investigator.
       I concurred that in the future, I would simply send the 
     reporters to Public Affairs. However, I am very much inclined 
     to believe that, on the basis of my personal, and documented, 
     knowledge of what transpired during the conversations I had 
     with Donna Henneman of DOJ/Office of Legal Counsel/Ethics 
     section, that * * * is not far from the truth: it's beginning 
     to sound like somebody, or multiple ``somebodies'' are trying 
     to carefully control the outcome of any investigation 
     surrounding the RTC referrals, and that the beginnings of a 
     cover-up may have already started months ago.
                                  ____



                                 Resolution Trust Corporation,

                                 Washington, DC, January 14, 1994.


                               memorandum

     To: Vice Presidents, Assistant Vice Presidents.
     From: Jack Ryan, Deputy CEO.
     Re: Madison Guaranty Savings and Loan Association.

       The RTC has received numerous requests for information on 
     Madison Guaranty Savings and Loan Association and related 
     matters. Interim CEO Roger Altman is committed to responding 
     to these requests as promptly and thoroughly as possible.
       In order to assure that the RTC's response to requests on 
     these matters is thorough, accurate, and timely, I have 
     established a working group to coordinate the collection and 
     distribution of all information and material responsive to 
     the requests. The working group is comprised of James Dudine, 
     William Collishaw, and Peter Knight.
       I am sure that I can count on the full cooperation of you 
     and your staff with the working group. Please see that this 
     memorandum is distributed to the appropriate staff.
                                  ____

     To: L. Richard Iorio and Dennis M. Cavinaw.
     From: James R. Dudine.
     Date: Tuesday, January 25, 1994.

       At the request of General Counsel Kulka and Deputy CEO 
     Ryan, PLS and The Washington Office of Investigations have 
     established a team to ascertain if any liability claims 
     remain viable as a result of the recent legislation extending 
     the statute of limitations from two to five years. In this 
     case the resurrected statute expires at the end of February 
     1994.
       Gary Watts of my staff, assisted by Tom Murray will be 
     visiting your office this week and next. Please give them 
     access to all records and workpapers, and to knowledgeable 
     members of your staff, including records and documents that 
     are covered by a Federal Grand Jury Subpoena.
       Gary and Tom will be working with a team of PLS attorneys 
     headed by Sr. Counsel Mark Gabrellian and including Terry 
     Arbit, Jim Igo, April Breslaw, Carl Gamble and Suzanne Rigby. 
     The objective is to complete the review of claims potential 
     by next week. In addition the team will assist in compiling a 
     detailed history of events, including the criminal referral 
     and document control issues, to assist RTC management in 
     communicating in a factual and unified way to Treasury and 
     Justice officials, the special counsel and to appropriate 
     committees and members of Congress.
                                  ____

     To: L. Richard Iorio, Lee O. Ausen, Michael X. Caron.
     From: L. Jean Lewis.
     Date: Monday, February 7, 1994.

       This is to advise you that I've had a conversation this 
     morning with AUSA Fletcher Jackson of the U.S. Attorney's 
     office in Little Rock. I called Mr. Jackson last week to make 
     an inquiry regarding Independence Federal Savings in 
     Batesville, Arkansas, out of which he had prosecuted a case 
     regarding Duane Kepford sent me a memo quite some time ago 
     about another; I recalled in having done a preliminary review 
     of Independence, that Edney was given immunity for 
     cooperating. I called Mr. Jackson last week to verify that 
     fact, which he in turn did verify when he called back.
       Mr. Jackson called Friday afternoon, and as I was out of 
     the office, I intended to call him back this morning. Before 
     I had the opportunity to call him, he called me.
       We discussed, and he then changed the topic by asking me if 
     Steve Irons had told me last fall not to talk to Fletcher. I 
     told him that I preferred not to answer the question. He then 
     stated that he ``didn't have much use for ether Steve Irons 
     or Gretchen Hall'', and wanted to know what I'd been told. I 
     advised him that Steve Irons had told me last fall that he 
     thought it was a good idea if we (being Steve and myself) 
     didn't talk to each other for a while about Madison. I 
     further added that if had been suggested to me by my 
     management here that any questions directed to me by the U.S. 
     Attorney's office should probably come through Steve Irons or 
     another FBI agent, and that since the FBI was my most 
     appropriate contact, I should funnel responses to any 
     questions through them. Mr. Jackson made a comment that he, 
     and he was just looking for some input from me. He didn't get 
     any.
       He then added that he'd spoken to Jeff Gerrish recently, 
     and that Gerrish was ``absolutely astounded'' that nothing 
     more was ever done criminally with Madison, beyond the Castle 
     Grande transaction. He asked me if I knew who Gerrish was; I 
     advised him that year, I knew Jeff Gerrish, and no, I was not 
     aware of Mr. Gerrish's opinions regarding the prosecution of 
     criminal actions out of Madison, and that I'd formed by own 
     conclusions on that point, and that's where they would stay--
     my own. I then advised Mr. Jackson that I did not wish to 
     discuss Madison Guaranty, and we could change the subject, or 
     hang up. He persisted, and I explained to him that I'd 
     developed a respect for him during the past 2\1/2\ years, and 
     that out of respect for the working relationship we've 
     previously had, I wasn't going to talk about Madison. We then 
     hung up after a coridal goodbye.
                                  ____

     To: Thomas L. Hindes, James R. Dudine, L. Richard Iorio, Glen 
         A. Penrose, April A. Breslaw, David G. Eisenstein, 
         Russell F. Kaufman, Philip J. Adams.
     From: Julie F. Yanda.
     Date: Wednesday, January 5, 1994.

       Today at 1:30 p.m., Russ Kaufman and I received word that 
     OCOS wanted to talk to us about the Madison Guaranty 
     ``investigation''. We met with representatives of both WDC 
     and KCO OCOS: Leonard Newmark (WDC), Michael Kohn (KCO) and a 
     third individual whose name I cannot now remember. When Russ 
     asked who had sent them to talk to us, Mr. Newmark replied 
     that it had been his supervisor who had sent them and who had 
     instructed them to be ``proactive'' in dealing with the 
     issues this case would raise. Mr. Newmark indicated that they 
     were not conducting an investigation, but rather an 
     ``inquiry''.
       The first question they asked was who had made the criminal 
     referral on Madison Guaranty. Russ indicated that the 
     referrals were made in accordance with RTC policy and 
     committed to providing Mr. Kohn with a copy of the RTC 
     policy. There was no further discussion of the referrals.
       The second series of questions they asked dealt with what 
     they characterized as ``fitness and integrity'' issues 
     concerning the Rose Law Firm. First, they asked what 
     investigation PLS had done into the representations the Rose 
     Firm had made to state regulators to convince the regulators 
     that Madison should remain open. I replied that PLS only 
     investigates issues dealing with professional malpractice and 
     that such inquiries would be made only in the context of 
     conflict of interests issues involving outside counsel. I 
     then explained that this case was not regionalized and that 
     April had served as the PLS attorney on this case. Second, 
     they asked who was the FDIC ``conflicts contact'' on this 
     case. Third, they asked what information we had concerning 
     the audit report the Rose Firm had used to convince 
     regulators that Madison should remain open and then later 
     relied upon in a malpractice claim against Frost & Co. Again, 
     I told them that I had no information concerning these 
     issues.
       Our discussion lasted no more than 10 minutes. Russ and I 
     then called Richard Iorio and discussed with him the 
     substance of our conversation with OCOS.
                                  ____



                                                Rose Law Firm,

                                 Little Rock, AR, October 10, 1983
     Mr. James B. McDougal,
     Chairman of the Board, Bank of Kingston,
     Kingston, AR.
       Dear Jim: Pursuant to your discussion with Hillary Rodham 
     Clinton, I am enclosing herewith a copy of our firm 
     statement, dated December 23, 1981, covering services 
     rendered in connection with the matter of the First National 
     Bank of Huntsville v. Madison Bank and Trust.
           Very truly yours,
                                                  C.J. Giroir, Jr.
       Enclosures.


                                                Rose Law Firm,

                               Little Rock, AR, December 23, 1981.
     Mr. James B. McDougal,
     Chairman of the Board, Bank of Kingston,
     Kingston, AR.
For legal services and professional advice rendered by Vincent 
  Foster, Jr., Carol Arnold and Mary Ellen Russell subsequent to our 
  billing dated December 23, 1981, through May 15, 1982 in 
  connection with the matter of First National Bank of Huntsville v. 
  Madison Bank and Trust; Madison Chancery E-81-112...........$5,000.00
Costs advanced subsequent to our billing dated December 23, 1981, 
    through July 31, 1982:
  Long distance telephone........................................$91.17
  Xerox charges...................................................21.40
  Extraordinary postage............................................1.56
  Package delivery expenses........................................6.70
  Supreme Court Clerk............................................100.00
  Computer Research...............................................92.70
  Trevathan Printing Company.....................................580.10
                                                             __________

      Total costs................................................893.63
                                                               ==========
_______________________________________________________________________

Total fees and costs..........................................$5,893.63
                                  ____


                              [Memorandum]

                                                 February 7, 1985.
     To: Governor Bill Clinton.
     From: Jim McDougal.

       Kathy called yesterday to ask for my recommendations for 
     two people to fill the vacancies on the State Savings and 
     Loan Board.
       For the industry position from the 2nd Congressional 
     District, I recommend John Latham, who is chairman of the 
     board of Madison Guaranty Savings and Loan Association. Mr. 
     Latham is a CPA and a licensed attorney. He is a major 
     contributor to your campaign. His board of directors is 50% 
     Black, giving his institution the largest minority 
     representation of any financial institution in the state.
       For the consumer position from the 4th Congressional 
     District, I recommend Dr. Jerry Kendall of Camden. Dr. 
     Kendall is a popular figure at Camden. His wife, Nancy from 
     Magnolia, is widely and favorably know. Their complete 
     support of your administration is a certainty.
       Bill, we are down to only about 15 state chartered savings 
     and loan institutions and I am about the only one around who 
     has any interest in this board.
                                  ____

                                                December 12, 1994.
     Mr. Ron Proctor,
     Citizens Bank,
     Flippin, AR.
       Dear Ron: I have been unsuccessful in trying to meet with 
     Bill and Hillary to sign the note renewal. I have forwarded 
     to them by messenger this morning the note and an envelope 
     with which to forward it to you.
       Each month we will deposit into our account at Flippin an 
     amount sufficient to cover the monthly payment.
       Thank you very much for your patience and tolerance in this 
     matter.
           Sincerely,
                                                James B. McDougal,
                                        Whitewater Development Co.
                                  ____


                              [Memorandum]

                                                   April 18, 1985.
     To: John Latham
     From: Jim McDougal.
       I want this preferred stock matter cleared up immediately 
     as I need to go to Washington to sell stock.
                                  ____


                              [Memorandum]

     February 19, 1985
     To: John Latham
     From: Jim McDougal
     Subject: Harvey Bell Cars.
       He wants us to do a leasing arrangement on his funeral 
     cars. Please assign someone to discuss this with him. His 
     number is 376-1600.
       Proceed with your idea on the subordinated notes. We need 
     to make a decision on Madison Bank & Trust.
       I need to close on my house loan and commercial loan 
     pronto.
                                  ____


                                 [Memo]

     January 7, 1985
     To: John
     From: Jim.
       1. See me about Steve Smith and Rolls Royce.
       2. You, Greg, and I need to discuss Securities License. 
     First South has one on by its Service Corporation.
       3. Ask Greg how we get a market survey for shopping center.
       4. We need to talk about how to handle first payment on the 
     90-day plan.

                                                    ------ ------.
                                                    ------ ------.
                                                    ------ ------.

                                  ____


                                 [Memo]

                                                    July 11, 1985.
     To: John Latham
     From: Jim McDougal.
       1. This is probably a good time to take in some 5-year 
     money cheap. Let's discuss rates.
       2. I need to know everything you have pending before the 
     Securities Commission as I intend to get with Hillary Clinton 
     within the next few days.
                                  ____


                             Index to Tabs

       Tab A--December 9, 1993 letters from Congressman Leach to 
     the Federal banking agencies requesting all documents related 
     to Madison Guaranty Savings and Loan and its subsidiaries.
       Tab B--March 8, 1994 letters from Congressman Leach to the 
     Office of Thrift Supervision (OTS) and the Resolution Trust 
     Corporation (RTC) requesting access to all documents related 
     to Madison Guaranty Savings and Loan and its subsidiaries, to 
     prepare for the RTC Oversight Hearings.
       Tab C--March 10, 1994 letters from Chairman Gonzalez to the 
     OTS and the RTC requesting that the agencies deny Congressman 
     Leach's document request.
       Tab D--March 14, 1994 letters from Chairman Gonzalez to the 
     Federal banking agencies and the RTC stating that the 
     agencies need not answer questions Madison at scheduled RTC 
     Oversight Hearings.
       Tab E--March 1, 1994 letter copied to Congressman William 
     Clinger.
       Tab F--Charts and other supporting documentation concerning 
     Whitewater's losses to Madison.


                               a. charts

       Total Arkansas State Chartered S&Ls from 1979 to 1992
       Madison Guaranty Rate of Growth
       Asset Growth of Madison Guaranty
       Payment of Clinton Loan by Madison Related Entity
       Funds from Madison Financial Corporation to Whitewater
       Funds Transferred from Madison Related Entities to the 
     Whitewater Development Corporation


                           b. other documents

       April 17, 1985 Board of Directors Meeting Minutes
       July 1, 1986 Memorandum from Jim McDougal to John Latham 
     concerning status of Madison Marketing
       February 3, 1994 letter from Congressman Leach to Roger 
     Altman with attached staff memorandum on links between 
     Madison and Whitewater

                                [Tab A]

         House of Representatives, Committee on Banking, Finance 
           and Urban Affairs,
                                 Washington, DC, December 9, 1993.
     Mr. Andrew C. Hove,
     Acting Director, Federal Deposit Insurance Corporation, 
         Washington, DC.
       Dear Mr. Hove: I am writing in reference to the House 
     Banking Committee Minority investigation of the failure of 
     Madison Guaranty Savings and Loan (Madison). As you know, 
     Madison was taken over by federal regulators in March 1989 
     and resolved by the Resolution Trust Corporation (RTC) in 
     November, 1990.
       To assist in this investigation, I request that the Federal 
     Deposit Insurance Corporation (FDIC) provide access to all 
     documents related to Madison and its subsidiaries. Such 
     documents would include, but not be limited to, 
     administrative files, examination reports, interoffice 
     memorandum, notes and minutes of meetings (including 
     telephonic meetings), correspondence, electronic mail, and 
     agreements the FDIC entered into with private sector firms to 
     perform legal and other services related to Madison. In 
     addition to documents in possession at FDIC-Washington, I 
     request access to all documents related to Madison held at 
     FDIC field offices. Furthermore, please provide the names and 
     titles of all FDIC employees involved with the examination 
     and supervision of Madison.
       Please have your staff contact Mike McGarry at 202-225-2258 
     to discuss arrangements to review the aforementioned 
     documents as soon as possible.
       I appreciate your assistance and look forward to your 
     cooperation.
           Sincerely,
                                                   James A. Leach,
                                                   Ranking Member.
                                  ____

         House of Representatives, Committee on Banking, Finance 
           and Urban Affairs,
                                 Washington, DC, December 9, 1993.
     Mr. Joe Madden,
     Commissioner, Arkansas Securities Department, Little Rock, 
         AR.
       Dear Mr. Madden: I am writing in reference to the House 
     Banking Committee Minority investigation of the failure of 
     Madison Guaranty Savings and Loan (Madison). As you know, 
     Madison was taken over by federal regulators in March 1989 
     and resolved by the Resolution Trust Corporation (RTC) in 
     November, 1990.
       To assist in this investigation, I request that the 
     Arkansas Securities Department provide access to all 
     documents related to Madison and its subsidiaries. Such 
     documents would include, but not be limited to administrative 
     files, examination reports, interoffice memorandum, notes and 
     minutes of meetings (including telephonic meetings), 
     correspondence, electronic mail, and supervisory actions. 
     Furthermore, please provide the names and titles of all State 
     Securities Department employees involved with the examination 
     and supervision of Madison.
       Please have your staff contact Mike McGarry at 202-225-2258 
     to discuss arrangements to review these documents as soon as 
     possible.
       I appreciate your assistance and look forward to your 
     cooperation.
           Sincerely,
                                                   James A. Leach,
                                                   Ranking Member.
                                  ____

         House of Representatives, Committee on Banking, Finance 
           and Urban Affairs,
                                 Washington, DC, December 9, 1993.
     Mr. Erskine Bowles,
     Administrator, Small Business Administration, Washington, DC.
       Dear Mr. Bowles: I am writing in reference to the House 
     Banking Committee Minority investigation of the failure of 
     Madison Guaranty Savings and Loan (Madison). As you know, 
     Madison was taken over by federal regulators in March of 1989 
     and resolved by the Resolution Trust Corporation (RTC) in 
     November, 1990.
       To assist in this investigation, I request that the Small 
     Business Administration (SBA) provide access to all documents 
     related to Madison and its subsidiaries, the Whitewater 
     Development Corporation, and Capital Management Services, 
     Inc. Such documents would include, but not be limited to, 
     administrative files, interoffice memorandum, notes and 
     minutes and meetings (including telephonic meetings), 
     correspondence, electronic mail, and loan applications and 
     approvals. Furthermore, please provide the names and titles 
     of all SBA employees involved with these entities.
       Please have your staff contact Mike McGarry at 202-225-2258 
     to discuss arrangements to review these documents as soon as 
     possible.
       I appreciate your assistance and look forward to your 
     cooperation.
           Sincerely,
                                                   James A. Leach,
                                                   Ranking Member.
                                  ____

         House of Representatives, Committee on Banking, Finance 
           and Urban Affairs,
                                 Washington, DC, December 9, 1993.
     Mr. Jonathan Fiechter,
     Acting Director, Office of Thrift Supervision, Washington, 
         DC.
       Dear Mr. Fiechter: I am writing in reference to the House 
     Banking Committee Minority investigation of the failure of 
     Madison Guaranty Savings and Loan (Madison). As you know, 
     Madison was taken over by federal regulators in March of 1989 
     and resolved by the Resolution Trust Corporation (RTC) in 
     November, 1990.
       To assist in this investigation, I request that the Office 
     of Thrift Supervision (OTS) provide access to all documents 
     related to Madison and its subsidiaries. Such documents would 
     include, but not be limited to, administrative files, 
     examination reports, interoffice memorandum, notes and 
     minutes and meetings (including telephonic meetings), 
     correspondence, electronic mail. In addition to documents in 
     possession at OTS-Washington, I request access to all 
     documents related to Madison held at OTS field offices.
       Furthermore, please provide the names and titles of all OTS 
     employess involved with the examination and supervision of 
     Madison as well as those who were assigned to work with the 
     RTC when the institution was closed in 1989.
       Please have your staff contact Mike McGarry at 202-225-2258 
     to discuss arrangements to review the aforementioned 
     documents as soon as possible.
       I appreciate your assistance and look forward to your 
     cooperation.
           Sincerely,
                                                   James A. Leach,
                                                   Ranking Member.
                                  ____

         House of Representatives, Committee on Banking, Finance 
           and Urban Affairs,
                                 Washington, DC, December 9, 1993.
     Hon. Roger C. Altman,
     Interim Chief Executive Officer, Resolution Trust 
         Corporation, Washington, DC.
       Dear Mr. Altman: I am writing in reference to the House 
     Banking Committee Minority investigation of the failure of 
     Madison Guaranty Savings and Loan (Madison). As you know, 
     Madison was taken over by federal regulators in March of 1989 
     and resolved by the Resolution Trust Corporation (RTC) in 
     November 1990.
       To assist in this investigation, I request that the RTC 
     provide access to all documents related to Madison and its 
     subsidiaries. Such documents would include, but not be 
     limited to, administrative files, examination reports, 
     interoffice memorandum, notes and minutes of meetings 
     (including telephonic meetings), correspondence, electronic 
     mail, and agreements the RTC entered into with private sector 
     contractors during the resolution of Madison. In addition to 
     documents in possession at RTC-Washington, I request access 
     to all documents related to Madison held at RTC field 
     offices. Furthermore, please provide the names and titles of 
     all RTC employees involved with the disposition of Madison.
       Please have your staff contact Mike McGarry at 202-225-2258 
     to discuss arrangements to review the aforementioned 
     documents as soon as possible.
       I appreciate your assistance and look forward to your 
     cooperation.
           Sincerely,
                                                   James A. Leach,
                                                   Ranking Member.

                                [Tab B]

                                         House of Representatives,
                                     Committee on Banking, Finance


                                            and Urban Affairs,

                                    Washington, DC, March 8, 1994.
     Mr. Jonathan Fiechter,
     Acting Director, Office of Thrift Supervision, Washington, 
         DC.
       Dear Mr. Fiechter: I am writing in reference to the House 
     Banking Committee's statutorily mandated, semiannual RTC 
     Oversight Hearings which are scheduled for the end of March. 
     As you know, a major area of oversight at these hearings will 
     be the failure and resolution of Madison Guaranty Savings and 
     Loan, Little Rock, Arkansas. Madison was taken over by 
     federal regulators in March of 1989 and resolved by the 
     Resolution Trust Corporation (RTC) in November, 1990.
       As ranking Member of the House Banking Committee, I request 
     that the OTS provide the Committee with access to all 
     documents related to Madison and its subsidiaries. Members of 
     the Committee will need access to this material to prepare 
     for the upcoming hearings and to perform their ongoing 
     oversight responsibilities. (As I am sure you are aware, 
     documents provided to the Ranking Member are available to the 
     Committee as a whole under the Committee rules.) The 
     documents requested would include, but not be limited to, 
     administrative files, examination reports, interoffice 
     memorandum, notes and minutes of meetings (including 
     telephonic meetings), correspondence, electronic mail, and 
     agreements the RTC entered into with private sector 
     contractors during the resolution of Madison. In addition to 
     documents in possession at OTS-Washington, I request access 
     to all documents related to Madison held at OTS field 
     offices. Furthermore, please provide the names and titles of 
     all OTS employees involved with the supervision of Madison.
       Please have your staff contact Joe Seidel at (202)226-3241 
     or Mike McGarry at (202)225-2258 to discuss arrangements to 
     review the aforementioned documents as soon as possible. As 
     you are aware, I have previously requested access to these 
     documents for use in performing other Committee functions. My 
     final letter concerning that request, was forwarded 
     yesterday, March 7, 1994. If the agency decides to comply 
     with that request, we will, of course, consider this request 
     satisfied as well.
       I appreciate your assistance and look forward to your 
     cooperation.
           Sincerely,
                                                   James A. Leach,
                                                   Ranking Member.
                                  ____

         House of Representatives Committee on Banking, Finance 
           and Urban Affairs,
                                    Washington, DC, March 8, 1994.
     John E. Ryan,
     Deputy Chief Executive Officer, Resolution Trust Corporation, 
         Washington, DC.
       Dear Mr. Ryan: I am writing in reference to the House 
     Banking Committee's statutorily mandated, semi-annual RTC 
     Oversight Hearings which are scheduled for the end of March. 
     As you know, a major area of oversight at these hearings will 
     be the failure and resolution of Madison Guaranty Savings and 
     Loan, Little Rock, Arkansas. Madison was taken over by 
     Federal regulators in March of 1989 and resolved by the 
     Resolution Trust Corporation (RTC) in November, 1990.
       As ranking Member of the House Banking Committee, I request 
     that the RTC provide the Committee with access to all 
     documents related to Madison and its subsidiaries. Members of 
     the Committee will need access to this material to prepare 
     for the upcoming hearings and to perform their ongoing 
     oversight responsibilities. (As I am sure you are aware, 
     documents provided to the Ranking Member are available to the 
     Committee as a whole under the Committee rules.) The 
     documents requested would include, but not be limited to, 
     administrative files, examination reports, interoffice 
     memorandum, notes and minutes of meetings (including 
     telephonic meeting), correspondence, electronic mail, and 
     agreements the RTC entered into with private sector 
     contractors during the resolution of Madison. In addition to 
     documents in possession at RTC-Washington, I request access 
     to all documents related to Madison held at RTC field 
     offices. Furthermore, please provide the names and titles of 
     all RTC employees involved with the disposition of Madison.
       Please have your staff contact Joe Seidel at (202)226-3241 
     or Mike McGarry at (202)225-2258 to discuss arrangements to 
     review the aforementioned documents as soon as possible. As 
     you are aware, I have previously requested access to these 
     documents for use in performing other Committee functions. My 
     final letter concerning that request, was forwarded 
     yesterday, March 7, 1994. If the agency decisions to comply 
     with the request, we will, of course, consider this request 
     satisfied as well.
       I appreciate you assistance and look forward to your 
     cooperation
           Sincerely,
                                                    James A Leach,
                                                   Ranking Member.

                                [Tab C]

                  Committee on Banking, Finance and Urban Affairs,
                                   Washington, DC, March 10, 1994.
     Mr. Jonathan Fiechter,
     Acting Director, Office of Thrift Supervision, Washington, 
         DC.
       Dear Mr. Fiechter: You have recently received letters from 
     Congressman Jim Leach requesting access to all documents you 
     possess concerning Madison Guaranty Savings and Loan and its 
     subsidiaries. The March 8, 1994 letter states that, ``Members 
     of the Committee will need access to this material to prepare 
     for the upcoming [RTC oversight] hearings and to perform 
     their ongoing oversight responsibilities.''
       This letter is to inform you that the Banking Committee is 
     not conducting an investigation of Madison Guaranty Savings 
     and Loan or related matters at this time. Mr. Leach's 
     requests do not constitute a Rule X or Rule XI investigation 
     under the House Rules. A hearing does not provide the basis 
     for a member of Congress to obtain documents to which he or 
     she is not otherwise entitled. I will request any information 
     needed by the Committee in order to prepare for any Thrift 
     Depositor Protection Board Oversight hearings pursuant to 
     section 21A(k)(6) of the FHLB Act and will make it available 
     to members of the Committee, as appropriate.
       I trust that you will give Congressman Leach's requests the 
     consideration they merit and extend to him the same 
     courtesies you would extend to any member of Congress.
           Sincerely,
                                                Henry B. Gonzalez,
                                                         Chairman.
                                  ____

                   Committee on Banking, Finance and Urban Affairs
                                  Washington, DC, March 10, 19094.
     Mr. John E. Ryan,
     Deputy Chief Executive Officer, Resolution Trust Corporation, 
         Washington, DC.
       Dear Mr. Ryan: You have recently received letters from 
     Congressman Jim Leach requesting access to all documents you 
     possess concerning Madison Guaranty Savings and Loan and its 
     subsidiaries. The March 8, 1994 letter states that, ``Members 
     of the Committee will need access to this material to prepare 
     for the upcoming [RTC oversight] hearings and to perform 
     their ongoing oversight responsibilities.''
       This letter is to inform you that the Banking Committee is 
     not conducting an investigation of Madison Guaranty Savings 
     and Loan or related matters at this time. Mr. Leach's 
     requests do not constitute a Rule X or Rule XI investigation 
     under the House Rules. A hearing does not provide the basis 
     for a member of Congress to obtain documents to which he or 
     she is not otherwise entitled. I will request any information 
     needed by the Committee in order to prepare for any Thrift 
     Depositor Protection Board Oversight hearings pursuant to 
     section 21A(k)(6) of the FHLB Act and will make it available 
     to members of the Committee, as appropriate.
       I trust that you will give Congressman Leach's requests the 
     consideration they merit and extend to him the same 
     courtesies you would extend to any member of Congress.
           Sincerely,
                                                Henry B. Gonzalez,
                                                         Chairman.
                                  ____


                                [Tab D]


                                     House of Representatives,

                                   Washington, DC, March 14, 1994.
     Mr. Andrew C. Hove, Jr.,
     Acting Chairman, Federal Deposit Insurance Corporation, 
         Member, Thrift Depositor Protection Oversight Board, 
         Washington, DC.
       Dear Mr. Hove: You have previously been invited by letter 
     dated March 3, 1994 to appear before the Committee on 
     Banking, Finance and Urban Affairs for the purpose of the 
     semiannual appearance of the Thrift Depositor Protection 
     Oversight Board. I expect that Republican members of the 
     Committee may use the opportunity of the Oversight Board 
     hearing to pursue extraneous matters, including Madison 
     Guaranty Savings and Loan. Any questions regarding Madison 
     Guaranty Savings and Loans, matters that are the subject of 
     pending investigations by Special Counsel Fiske or other law 
     enforcement authorities, or other extraneous matters not 
     specifically set forth in section 21A(k)(6) of the Federal 
     Home Loan Bank Act or the March 3, 1994 invitation letter 
     will not be considered pertinent at the hearing and need not 
     be answered by you.
       I was the primary sponsor of the provision to require the 
     Oversight Board to appear on a semiannual basis so that the 
     Committee could oversee its activities. The recent 
     appropriation of funds to the RTC, the management reforms, 
     and FDIC-RTC transition measures required under Public Law 
     103-24 clearly require the complete and full attention of the 
     Committee in order to have a successful Oversight Board 
     hearing. I intend to keep the hearing so focused.
       I look forward to your March 4, 1994 appearance.
           Sincerely,
                                               Henery B. Gonzalez,
                                                         Chairman.
                                  ____

                                   Washington, DC, March 14, 1994.
     Hon. Alan Greenspan,
     Chairman, Board of Governors of the Federal Reserve System, 
         Member, Thrift Depositor Protection Oversight Board, 
         Washington, DC.
       Dear Mr. Greenspan: You have previously been invited by 
     letter dated March 3, 1994 to appear before the Committee on 
     Banking, Finance and Urban Affairs for the purpose of the 
     semiannual appearance of the Thrift Depositor Protection 
     Oversight Board. I expect that Republican members of the 
     Committee may use the opportunity of the Oversight Board 
     hearing to pursue extraneous matters, including Madison 
     Guaranty Savings and Loan. Any questions regarding Madison 
     Guaranty Savings and Loans, matters that are the subject of 
     pending investigations by Special Counsel Fiske or other law 
     enforcement authorities, or other extraneous matters not 
     specifically set forth in section 21A(k)(6) of the Federal 
     Home Loan Bank Act or the March 3, 1994 invitation letter 
     will not be considered pertinent at the hearing and need not 
     be answered by you.
       I was the primary sponsor of the provision to require the 
     Oversight Board to appear on a semiannual basis so that the 
     Committee could oversee its activities. The recent 
     appropriation of funds to the RTC, the management reforms, 
     and FDIC-RTC transition measures required under Public Law 
     103-24 clearly require the complete and full attention of the 
     Committee in order to have a successful Oversight Board 
     hearing. I intend to keep the hearing so focused.
       I look forward to your March 4, 1994 appearance.
           Sincerely,
                                                Henry B. Gonzalez,
                                                         Chairman.
                                  ____



                                     House of Representatives,

                                   Washington, DC, March 14, 1994.
     Mr. Jonathan Fiechter,
     Acting Director, Office of Thrift Supervision, Member, Thrift 
         Depositor Protection Oversight Board, Washington, DC.
       Dear Mr. Fiechter: You have previously been invited by 
     letter dated March 3, 1994 to appear before the Committee on 
     Banking, Finance and Urban Affairs for the purpose of the 
     semiannual appearance of the Thrift Depositor Protection 
     Oversight Board. I expect that Republican members of the 
     Committee may use the opportunity of the Oversight Board 
     hearing to pursue extraneous matters, including Madison 
     Guaranty Savings and Loan. Any questions regarding Madison 
     Guaranty Savings and Loans, matters that are the subject of 
     pending investigations by Special Counsel Fiske or other law 
     enforcement authorities, or other extraneous matters not 
     specifically set forth in section 21A(k)(6) of the Federal 
     Home Loan Bank Act or the March 3, 1994 invitation letter 
     will not be considered pertinent at the hearing and need not 
     be answered by you.
       I was the primary sponsor of the provision to require the 
     Oversight Board to appear on a semiannual basis so that the 
     Committee could oversee its activities. The recent 
     appropriation of funds to the RTC, the management reforms, 
     and FDIC-RTC transition measures required under Public Law 
     103-24 clearly require the complete and full attention of the 
     Committee in order to have a successful Oversight Board 
     hearing. I intend to keep the hearing so focused.
       I look forward to your March 24, 1994 appearance.
           Sincerely,
                                                Henry B. Gonzalez,
                                                         Chairman.
                                  ____



                                     House of Representatives,

                                   Washington, DC, March 14, 1994.
     Hon. Lloyd Bentsen,
     Secretary of the Treasury, Chairman, Thrift Depositor 
         Protection Oversight Board, Washington, DC.
       Dear Mr. Secretary: You have previously been invited by 
     letter dated March 3, 1994 to appear and testify before the 
     Committee on Banking, Finance and Urban Affairs for the 
     purpose of the semiannual appearance of the Thrift Depositor 
     Protection Oversight Board. That letter specifies in detail 
     the matters to which you should direct your testimony. I 
     expect that Republican members of the Committee may use the 
     opportunity of the Oversight Board hearing to pursue their 
     stated interest in extraneous matters, including Madison 
     Guaranty Savings and Loan. Any questions regarding Madison 
     Guaranty Savings and Loans, matters that are the subject of 
     pending investigations by Special Counsel Fiske or other law 
     enforcement authorities, or other extraneous matters not 
     specifically set forth in section 21A(k)(6) of the Federal 
     Home Loan Bank Act or the March 3, 1994 invitation will not 
     be considered pertinent at the hearing and need not be 
     answered by you.
       I was the primary sponsor of the provision to require the 
     Oversight Board to appear on a semiannual basis so that the 
     Committee could oversee its activities. The recent 
     appropriation of funds to the RTC, the management reforms, 
     and FDIC-RTC transition measures required under Public Law 
     103-24 clearly require the complete and fully attention of 
     the Committee in order to have a successful Oversight Board 
     hearing. I intend to keep the hearing so focused.
       I look forward to your March 24, 1994 appearance.
           Sincerely,
                                                Henry B. Gonzalez,
                                                         Chairman.
                                  ____



                                     House of Representatives,

                                   Washington, DC, March 14, 1994.
     Hon. Roger Altman,
     Chief Executive Officer, Resolution Trust Corporation, 
         Member, Thrift Depositor Protection Oversight Board, 
         Washington, DC.
       Dear Mr. Altman: You have previously been invited by letter 
     dated March 3, 1994 to appear before the Committee on 
     Banking, Finance and Urban Affairs for the purpose of the 
     semiannual appearance of the Thrift Depositor Protection 
     Oversight Board. I expect that Republican members of the 
     Committee may use the opportunity of the Oversight Board 
     hearing to pursue extraneous matters, including Madison 
     Guaranty Savings and Loan. Any questions regarding Madison 
     Guaranty Savings and Loans, matters that are the subject of 
     pending investigations by Special Counsel Fiske or other law 
     enforcement authorities, or other extraneous matters not 
     specifically set forth in section 21A(k)(6) of the Federal 
     Home Loan Bank Act or the March 3, 1994 invitation letter 
     will not be considered pertinent at the hearing and need not 
     be answered by you.
       I was the primary sponsor of the provision to require the 
     Oversight Board to appear on a semiannual basis so that the 
     Committee could oversee its activities. The recent 
     appropriation of funds to the RTC, the management reforms, 
     and FDIC-RTC transition measures required under Public Law 
     103-24 clearly require the complete and full attention of the 
     Committee in order to have a successful Oversight Board 
     hearing. I intend to keep the hearing so focused.
       I look forward to your March 24, 1994 appearance.
           Sincerely,
                                                Henry B. Gonzalez,
                                                         Chairman.

                                [Tab E]


                                     House of Representatives,

                                    Washington, DC, March 1, 1994.
     Hon. Carol K. Browner,
     Administrator, U.S. Environmental Protection Agency, 
         Washington, DC.
       Dear Madam Administrator: You have recently received a 
     request from various minority members of the Committees on 
     Armed Services, Energy and Commerce, Government Operations, 
     and Natural Resources for information concerning the Waste 
     Isolation Pilot Plant (WIPP) Test Phase. Their letter 
     requests answers to a number of questions concerning WIPP as 
     well as numerous documents, and cites Rules X and XI of the 
     House of Representatives as the basis for the request.
       This letter is to inform you that the above mentioned 
     committees have no ongoing investigations of the WIPP Test 
     Phase at this time. Therefore, the minority members' request 
     does not constitute a Rule X or Rule XI investigation under 
     the House Rules.
       This is not intended in any way to direct the nature of 
     your response to that letter. Indeed, we expect that you 
     would show the members the same courtesies as you would any 
     member of Congress.
           Sincerely,
     John Conyers, Jr.,
                        Chair, Committee on Government Operations.
     George Miller,
                            Chair, Committee on Natural Resources.
     John D. Dingell,
                          Chair, Committee on Energy and Commerce.
     Ronald V. Dellums,
                               Chair, Committee on Armed Services.

                                [Tab F]

       Charts not reproducible in the Record.

Minutes of Meeting, Board of Directors, Madison Financial Corporation, 
                             April 17, 1985

       The Board of Directors of Madison Financial Corporation met 
     on April 17, 1985, at 1:00 p.m. at the offices of Madison 
     Financial Corporation at 16th and Main Streets, Little Rock, 
     Arkansas. All directors were present. The minutes of the 
     previous meeting were read and approved as recorded.
       The first order of business, introduced by John Latham, was 
     the matter of authorizing prepayment of Jim McDougal's bonus. 
     After a full discussion, the following resolution was 
     unanimously adopted, with Jim McDougal abstaining from the 
     voting: ``RESOLVED, that the Corporation pre-pay to Jim 
     McDougal $30,000.00 of his annual bonus in recognition of the 
     profits of the prior year, and that said bonus is to be paid 
     directly to Whitewater Development.''
       There being no further business, the meeting was adjourned.
                                                James B. McDougal,
                                                         Chairman.
                                  ____



                                  Memo

     To: John Latham.
     From: Jim McDougal.
     Date: July 1, 1986.

     Madison Marketing
       When the service corporation undertook its first land 
     development project in the spring of 1983, it was determined 
     to primarily advertise the home sites through the use of 
     television. The firm of Rothman and Lowery was retained as 
     Madison's advertising agency. Because her education is in 
     speech and drama, Mrs. McDougal assisted in preparing of copy 
     for the commercials, appeared in the commercials, and 
     assisted in editing the commercials. She either wrote or 
     rewrote all newspaper copy to advertise the subdivision. 
     Until the summer of 1984, the corporation undertook the 
     development of other subdivisions in addition to Maple Creek 
     Farms.
       During this period the creative audio and visual quality of 
     the production produced for the media by Rothman and Lowery 
     progressively deteriorated. Additionally, the firm frequently 
     made mistakes as to the placement of advertising or omitted 
     to place advertising when instructed to do so.
       In late summer 1984, after advising the board of directors 
     of the savings and loan and after seeking the legal opinion 
     from counsel, Mrs. McDougal formed Madison Marketing. She 
     undertook, with hired assistants, the writing of copy, taping 
     of spots, and placement of advertising for both the savings 
     and loan and the service corporation. For the work she 
     received exactly the same fee which had been paid Rothman and 
     Lowery, with the exception of the fact that she did not 
     charge for production of television spots or the writing of 
     newspaper copy.
       Additionally, she negotiated a much lower rate structure 
     with the television stations than the company had been paying 
     when the ads were placed through Rothman and Lowery. In late 
     January, 1985, Mrs. McDougal permitted Madison Marketing to 
     become a subsidiary of Madison Financial Corporation. Because 
     Madison Marketing was at this point a ``recognized agency'' 
     by the electronic media, this resulted in Madison Financial 
     Corporation receiving the 15 percent discount normally given 
     advertising agencies. Mrs. McDougal continues to perform all 
     the aforementioned duties in connection with the company's 
     advertising at no fee.
     Madison Real Estate
       When initial sales began at Maple Creek Farms in April of 
     1983, the listing broker was Perryman Realty Company, Inc. 
     Mr. Perryman had, at this time, other interests including his 
     own subdivisions. This prohibited his devoting the seven days 
     a week necessary to the sales effort then under way at Maple 
     Creek Farms and his listing was terminated.
       Some of Mr. Perryman's better salesmen desired to remain at 
     Maple Creek and continue selling. However, Arkansas law 
     requires that real estate salesmen be under the direct 
     supervision of a licensed real estate broker. Mrs. McDougal 
     holds a valid broker's license. In 1983, her license was held 
     under the name ``McDougal Real Estate'' although she was not 
     actively involved in the sale of real estate at this time.
       Upon the termination of Mr. Perryman's activities, Mrs. 
     McDougal changed the name of her real estate company to 
     ``Madison Real Estate Company''. Madison Real Estate became a 
     wholly owned subsidiary of Madison Financial Corporation. 
     From that time until the present, Mrs. McDougal has performed 
     the duty of supervision broker for the various salesmen 
     working for Madison Real Estate. Although it is normal 
     practice that the supervising broker receives at least thirty 
     percent of commissions generated by the salesmen under their 
     supervision, Mrs. McDougal charged no such fees. The only 
     fees Mrs. McDougal has received from Madison Real Estate are 
     fees for sales she made personally.
     Sorenson Enterprises
       Sorenson Enterprises is a sole proprietorship owned by Erik 
     Sorenson. Mr. Sorenson is a general contractor engaged in 
     construction and landscaping work. He built the sales office 
     for the subdivision at Camden known as Greentree Farms. He 
     also built the sales office at Fair Oaks. At several of our 
     subdivisions in southern Arkansas, he supervised the painting 
     and erection of signs in entranceways. He employed in these 
     subdivisions a crew of men engaged in selective clearing of 
     trees, planting of grass, and the general beautification of 
     the subdivisions. Concurrent with this activity, Mr. Sorenson 
     was engaged in building houses for other persons unrelated to 
     this company.
       Because of the observed quality of his workmanship, he was 
     placed under Mr. Dutton's command at Little Rock, and given 
     the responsibility of constructing or making additions to 
     various houses at Maple Creek Farms owned by the company. 
     When the company undertook the development of Castle Grande 
     Estates, an arrangement was negotiated with Mr. Sorenson 
     whereby for a flat monthly fee he would supervise the 
     assembling of the modular houses and these duties involved 
     the preparation of footings and foundations, the adding of 
     brick trim, and supervision of correcting any defect in 
     the workmanship of the house, and supervision of the 
     installation of central air conditioning and utilities.
     Madison Properties
       Madison Properties assets consists primarily of a very 
     large masonry building located on several acres with two 
     producing gas wells in Madison County just south of the 
     county seat of Huntsville. Madison Properties has no 
     connection to Madison Guaranty Savings and Loan or Madison 
     Financial Corporation.
     Master Developers
       Three stockholders are working in conjunction with the 
     development of 59 acres located on 145th Street. Two 
     stockholders have extensive experience in real estate 
     development and sales. These individuals have engaged in 
     exhaustive market research to determine immediate commercial 
     use for subject property. Their feasibility and marketing 
     studies indicate the immediate need for a fast-food outlet to 
     serve the several hundred industrial and service employees 
     presently employed within 1,500 feet of subject location. 
     There is no such outlet within several miles to serve the 
     heavily populated suburban areas surrounding the property. 
     Additional trade is anticipated from traffic generated by the 
     freeway which services the location.
       For the same reasons outlined above, need is indicated for 
     a convenience store and gasoline outlet. As mentioned above a 
     convenience store is essential to the successful sale of 
     residential lots. Roadrunner, Incorporation, a highly 
     successful Arkansas based convenience store and gasoline 
     outlet franchiser, has conducted an extensive market survey 
     which has concluded that such a facility located on subject 
     property would be successful. Two of the principals of Master 
     Developers have arranged for separate financing to erect such 
     a facility.
       Also, negotiations are far advanced for the sale of two 
     acres of the property to a building supply and insulation 
     firm.
       The preliminary master development plan for the business 
     park to be created is completed and a copy is attached.
     Island Construction
       The lots at Campobello which were under development last 
     year, were so heavily overgrown with spruce trees and other 
     foliage, that our sales people were finding it difficult to 
     walk the prospects from the road to the ocean therefore, 
     greatly inhibiting the sale of frontage lots.
       Additionally, the density of the foliage prohibited a view 
     of the ocean from the interior lots lying immediately behind 
     the ocean fronts lots, thereby diminishing the value of those 
     lots because of this lack of view of the water.
       Initially, unsuccessful attempts were made to employ timber 
     cutters with chain saws to selectively clear the ocean front 
     lots. This process proved too slow and too costly. When it 
     was determined that lot preparation could not keep pace with 
     sales using this method and further determined that this 
     process distracted from the beauty of the lots because it 
     left them covered with stumps, another solution was sought.
       Mr. Randolph, who was thoroughly familiar with the use of 
     mechanical methods employed by the company to prepare lots 
     for sale and who had had extensive experience working in 
     various subdivisions owned by the company, was asked to come 
     to Campobello to devise a method of overcoming this 
     landscaping and marketing problem. Upon his arrival he 
     immediately leased the proper bull dozer for such work and 
     trained bull dozer operators living on the island as to the 
     proper method of selectively clearing the lots and removal of 
     the resulting debris from the lots. Direct correlation by the 
     increasing sales and his arrival is easily demonstrative. For 
     example, every lot he caused to be prepared in his first week 
     of work was sold that weekend. His additional duties involved 
     building driveways which permitted access from the main 
     thoroughfare through the lot to the water's edge.
       The company owns a large tract of land abutting the highway 
     immediately at the entrance to the island. Our predecessor in 
     title had cut the timber from this tract some years ago. When 
     this sort of clear cutting occurs on that island, a large 
     bushy plant, which is quite unattractive, grows to a great 
     height and has an especially virulent root system which 
     inhibits its removal effectively even by a bull dozer. Mr. 
     Randolph purchased a new 70 horsepower tractor than attached 
     a device known as a ``tree eater'' to be used in the 
     eradication of this plant. This method was beautified to as 
     to make the ocean visible, thus greatly enhancing the value 
     of our entire property. Mr. Randolph left the tractor he 
     purchased at Campobello where it is in use until this time. 
     Personnel he trained in the proper method of beautification 
     of our property are continuing the process this year with 
     very beneficial effects.
                                  ____

                                     Committee on Banking, Finance


                                            and Urban Affairs,

                                 Washington, DC, February 3, 1994.
     Mr. Roger C. Altman,
     Interim CEO, Resolution Trust Corporation, Washington, DC.
       Dear Mr. Altman: I am in receipt of your February 1, 1994 
     response to the letter initiated by Senate Republican 
     leadership concerning Madison Savings and Loan and I am 
     pleased to learn that the RTC ``will vigorously pursue all 
     appropriate remedies'' with regard to Madison's failure. It 
     seems self-apparent that in order for the RTC to pursue 
     vigorously all remedies it must have all relevant information 
     at its disposal. Accordingly, I urge the RTC to seek and 
     review all Whitewater Development Corporation documents 
     turned over by the White House to the Justice Department.
       In its investigation of Madison, the Minority has uncovered 
     links between Madison and Whitewater, some of which may have 
     contributed to the thrift's failure. Not only did James and 
     Susan McDougal hold significant ownership interest in both 
     entities (approximately two thirds in Madison and one half in 
     Whitewater), but the other joint owners of Whitewater (Bill 
     and Hillary Clinton) appear to have benefited directly and 
     indirectly from the application of Madison resources. [See 
     the attached memo.]
       If the White House choose to use the Justice Department to 
     shield Whitewater documents not only from the public and 
     Congress, but from other government agencies, such as the 
     RTC, which have legitimate public law enforcement 
     responsibilities, it is hard to believe a responsible 
     resolution of the issues involved can be made by regulatory 
     authorities.
       I have high regard for your personal integrity, but as you 
     know, from the beginning, it has been an awkward situation to 
     have a presidentially appointed and confirmed officer of the 
     Treasury Department also head an independent federal agency, 
     the Resolution Trust Corporation (RTC). When this prospect 
     was first suggested at the beginning of the Clinton 
     Administration, it did not strike the Minority as overly 
     unreasonable for a month or two given the fact that no RTC 
     head had been selected.
       However, it has been over a year since the Administration 
     has been in office and it can only be described as 
     structurally unseemly for a political appointee of an 
     Executive branch department to make what are in effect, law 
     enforcement decisions for an independent federal agency as 
     they may touch upon the President.
       Accordingly, I would urge that you request from the 
     Department of Treasury's General Counsel and Ethics Office 
     advice as to whether you, as interim CEO of the RTC, are 
     obligated to rescue yourself from any decisions concerning 
     the resolution of Madison Guaranty. Just as the special 
     counsel law was designed to relieve the Attorney General from 
     an ethical dilemma of being both chief law enforcement 
     officer for the nation and chief legal advisor to the 
     President in circumstances when the President or a high level 
     Administration officer is the subject of investigation, so it 
     would appear ethically questionable for a political appointee 
     of the Department of Treasury to make decisions for an 
     independent federal agency when the President may be 
     implicated in enforcement and civil actions.
       In this regard, it should be clear that the issue is not 
     whether a presidentially appointed official can oversee an 
     investigation involving the President. Rather the issue is 
     that officials with this responsibility should be confirmed 
     for the job with that particular accountability. As you will 
     recall it was a political appointee confirmed by the Senate 
     that issued a cease and desist order for engaging in 
     conflicts of interest against the son of a former President.
       As you know, despite your strong letter to the Chairman of 
     the House Banking Committee recommending against extension, 
     Congress last year extended the statute of limitations for 
     civil lawsuits brought against S&L wrongdoers. As you pointed 
     out in your most recent letter, this extension ``has afforded 
     the RTC an opportunity to investigate further any civil 
     claims which may be asserted against individuals or entities 
     associated with Madison Guaranty for fraud, intentional 
     misconduct resulting in unjust enrichment, or international 
     misconduct resulting in substantial loss to the 
     institution.'' Given, however, the impending running of the 
     statute of limitations for certain kinds of actions, time is 
     clearly of the essence for the RTC to make judgments about 
     civil accountability in the failure of Madison.
       Finally, I would like to reiterate my request, pursuant to 
     Rules X and XI of the House Rules for all documents related 
     to Madison Guaranty Savings and Loan, Little Rock, Arkansas. 
     As you know, on December 9, 1993, I wrote the RTC requesting 
     access to all documents related to Madison Guaranty and 
     its subsidiaries.
       House and Committee Rules, House practices, and judicial 
     precedent support the proposition that the Ranking Minority 
     Member is the functional counterpart to the Chairman for 
     Committee action. This being the case, a request for 
     documents made by the Ranking Minority Member has parallel 
     standing with a request made by the Chairman of the 
     Committee. The Ranking Minority Member clearly has a voice in 
     the process and is entitled to information that will enable 
     the Ranking Minority Member to carry out his constitutionally 
     mandated oversight responsibilities.
       Therefore, the courtesy of a definitive reply to this 
     document request is requested by 12 noon, Monday, February 7, 
     1994. On this matter, it is urged that you also consult with 
     the Ethics Office as to the relevance of the previously 
     discussed recusal issue.
       Again, let me stress that to the degree a conflict 
     situation may exist in this matter in no way reflects on your 
     personal integrity. It is simply an awkward circumstance in 
     contrast to a personal embarrassment.
           Sincerely,
                                                   James A. Leach,
                                                   Ranking Member.
     Enclosure.

                               Memorandum

     To: Congressman Leach.
     From: Banking Minority Staff.
     Re: Madison Guaranty (``Madison'').
       In reviewing documents related to Madison in the possession 
     of Minority Banking, we have come across material which may 
     indicate direct payment of a loan of Bill Clinton's by 
     Madison through a subsidiary.
       Since the Minority's investigation is concerned with the 
     possible misuse of federally insured funds to assist 
     Whitewater and/or the former Governor, we thought we should 
     share the following information with you.


                                summary

       Based on documentary evidence available to the Minority, it 
     appears that Madison Marketing served, in at least one 
     instance, as a conduit of funds from Madison Guaranty to 
     Whitewater and Governor Clinton. If this is correct, it would 
     appear that insured funds from the failed Madison Guaranty 
     were diverted and directly benefitted the Governor and his 
     investment in Whitewater, a claim Clinton had denied.


                             documentation

       The 1983, Bill Clinton obtained a loan from Security Bank 
     of Paragould, Arkansas for approximately $20,800 (loan #975-
     585, Bill Clinton). The money from this loan was used to pay 
     off the remaining balance of a loan at Madison Bank and Trust 
     of Kingston, Arkansas that was provided for the purpose of 
     constructing a modular home on lot #13 at Whitewater Estates. 
     The loan at Madison Bank was provided in 1980 to Hillary 
     Clinton in the amount of $30,000.
       On November 8, 1985, James McDougal sent a letter 
     accompanied by a check to Charles Campbell, Vice President of 
     Security Bank of Paragould, for $7,322.42. The letter from 
     McDougal states that the check is principal and interest 
     payment on ``Note #957-585, Bill Clinton.'' [Note: It appears 
     that the loan number is a typographical error with the 
     superimposing of numbers 5 and 7 in the first three digits.]
       The check McDougal enclosed with his letter to Mr. Campbell 
     is a Whitewater Development Corporation check dated November 
     7, 1985. The loan number referenced on the memo portion of 
     the check is ``Note #95-585.''
       According to the check ledgers for the Whitewater 
     Development Corporation (WDC), the corporation's checking 
     account had the following balances: $189.50 on 10-10-85; and, 
     $12.49 on 10-31-85. However, in order to cover the payment of 
     $7,322.40 on the Clinton loan, a deposit is recorded on 
     November 8, 1985 in the amount of $7,500.00. The deposit is 
     listed as coming from ``Madison Marketing.''
       A 1986 Federal Home Loan Bank Board exam gives the 
     impression that Madison Marketing was largely a sham 
     corporation used to divert federally insured resources to 
     insiders. The exam notes that ``Until 1986, Susan McDougal 
     owned Madison Marketing.'' The report also states the 
     following:
       ``Madison Marketing is paid for doing all the general 
     advertising for Madison Guaranty and most of the advertising 
     for Madison Financial's land development projects. All of 
     Madison Marketing's business is derived from Madison Guaranty 
     or its subsidiaries. Since 1983 these payments total 
     $1,532,000.
       ``Given the evidence of Madison Marketing's invoices, it is 
     questionable how much of these advertising services are 
     actually performed by the firm. The actual work * * * appears 
     to be performed by others. It would appear that Madison 
     Guaranty could have an employee perform similar work for much 
     less money.
       ``Mr. Latham [an officer of Madison] stated that Madison 
     Marketing made no payments to any stockholders. This 
     statement is false. As part of a test for such payments, the 
     examiners discovered two remittances from Madison Marketing 
     to Susan McDougal [a large stockholder of Madison] which 
     total $50,000. This was a test, and there may be additional 
     payments.''


                               conclusion

       Given the above circumstances, it would appear that 
     federally insured deposits (i.e., funds from Madison Guaranty 
     through Madison Marketing), which, with the later failure of 
     Madison became, in effect, taxpayer obligations, were 
     transferred for the direct personal benefit of the former 
     Governor.
       The above payment also raises the question of whether 
     Whitewater was treated as an affiliate or related interest of 
     Madison Guaranty and therefore subject to conflict of 
     interest statutes. From a legal perspective, it could be 
     argued that the McDougals' controlling interest in Madison 
     Guaranty and their substantial ownership interest in 
     Whitewater could qualify Whitewater as an ``affiliate'' of 
     Madison Guaranty. Even if Whitewater is not considered a 
     subsidiary, related interest, or affiliate of Madison 
     Guaranty, such an extension of funds to a presumably 
     ``unaffiliated'' entity would be very unusual and suspect.
       It has been publicly reported, with respect to this loan 
     repayment, that both Whitewater and the Clintons took a tax 
     deduction related to interest paid on the same loan--which 
     the Clintons later recognized as improper double deduction 
     after an article ran in the New York Times. What remains 
     unclear is the largest question of whether the funds provided 
     by Madison to reduce the Clinton's liability were proper or 
     properly reported as income for income tax purposes.
       As you know, we have received broad hints from within the 
     RTC that the agency has had under review money transfers from 
     Madison to Whitewater. We will not know whether this type of 
     activity was more pervasive and part of a larger pattern 
     unless, and until, the agency provides us the documents we 
     have requested. If Madison provided any direct or indirect 
     assistance to Whitewater, presumably half the value of such 
     would redound to the advantage of each of the half owners. In 
     any regard, the above money transfer underscores that then 
     Governor Clinton had personal liabilities reduced by a 
     payment from Madison. Such payment presumably carries ethical 
     as well as tax implications and is part and parcel of the $47 
     to $60 million estimated taxpayer loss at Madison.
       Attachments.
                                               September 30, 1983.
     Governor Bill Clinton,
     Little Rock, AR.
       Dear Governor Clinton: Enclosed is a copy of our check 
     #12677 in the amount of $20,800.00 representing the proceeds 
     of your note. The original was mailed to: Madison Bank & 
     Trust, Kingston, Arkansas.
           Sincerely,
                                              Charles D. Campbell,
                                                   Vice President.
                                  ____



                                                 Jim McDougal,

                                Little Rock, AR, November 8, 1985.
     Mr. Charles D. Campbell,
     Vice President, Security Bank,
     Paragould, AR.
     Re: Note #957-585, Bill Clinton.
       Dear Mr. Campbell: Enclosed is a White Water Development 
     Corporation check for $7,322.42, representing principal 
     payment of $5,000 and interest payment of $2,322.42, on the 
     above note.
       Thank you for your attention to this matter.
           Sincerely,
                                                     Jim McDougal.

   In the Circuit Court of Pulaski County, Arkansas, Second Division

       MADISON GUARANTY SAVINGS AND LOAN ASSOCIATION, a State 
     Chartered Savings and Loan; MADISON FINANCIAL CORPORATION, a 
     Wholly Owned Subsidiary of Madison Guaranty Savings and Loan 
     Association, Plaintiffs, versus ERNST & CO., an Arkansas 
     Professional Association, and its directors James Alford, 
     Michael Robinson, Gary Grey, Gaines Morton, Tim Gibbon, Steve 
     Humphries, Alan Duncan, Frank Butts, Marjorie Itskowitz, John 
     Does A., B, C, D, Defendant. (No. 88-1193)


                        first amended complaint

       COKES NOW, Plaintiffs, and for cause of action states as 
     follows:

                                   I


                                parties

       1. Plaintiff Madison Guaranty Savings and Loan Association 
     (hereinafter, Madison Guaranty) is a state savings & loan 
     association duly chartered under the laws of the State of 
     Arkansas. Plaintiff Madison Financial Corporation 
     (hereinafter, Madison Financial) is a state chartered 
     corporation and wholly owned subsidiary of Madison Guaranty.
       2. Defendant Frost & Company is a professional association 
     or partnership of public accountants with its principal place 
     of business in Little Rock, Arkansas, comprised of the 
     following individual partners who are set forth as Defendants 
     in paragraph 3.

                           *   *   *   *   *

       7. John Latham at all relevant times was the President and 
     Chief Executive Officer of Madison Guaranty and a member of 
     its Board of Directors; and a member of the Board of 
     Directors and the Secretary of MFC.
       8. Susan McDougal was at all relevant times wife of James 
     B. McDougal, member of the Board of Directors of Madison 
     Guaranty, President of Madison Real Estate, a division of 
     MFC, and President of Madison Marketing, a service provider 
     to Madison Guaranty and MFC.
       9. Madison Real Estate was a real estate brokerage 
     operation owned and operated by Madison Financial with its 
     principal broker Susan McDougal.
       10. Madison Marketing was an advertising agency through 
     which Madison Financial and Madison Guaranty purchased all of 
     its advertising for itself and KFC's real estate 
     developments.
       11. Jim, David and Bill Kenley (``Kenley Brothers'') were 
     real estate agents and/or developers for Madison Real Estate, 
     who sold property and received substantial commissions and/or 
     development fees from Madison Financial.
       12. Frost & Company purported to serve as independent 
     auditor of Madison Guaranty and its consolidated subsidiary 
     Madison Financial for the years 1984 and 1985.
       13. James D. Alford at all relevant times was the audit and 
     accounting partner of Frost & Company in charge of the 
     Madison Guaranty audit.
       14. Federal Home Loan Bank Board (``FHLBB'') is the primary 
     federal regulator of Madison Guaranty. FHLBB has oversight of 
     the Federal Home Loan Bank of Dallas which has direct 
     supervisory responsibility for Madison Guaranty.

                           *   *   *   *   *


  Federal Home Loan Bank Board Office of Examinations and Supervision

       Name and Address of Institution Madison Guaranty Savings 
     and Loan Association, 1501 Main Street, Little Rock, Arkansas 
     72203.
       District Number 9, Docket Number 7601.
       Examination as of March 4, 1986.
       Service Corporations and Other Affiliates Examined: Madison 
     Financial Corporation.


                         report of examination

                  Prohibition of disclosure or release

       This document is the property of the Federal Home Loan Bank 
     Board and is furnished to the Institution for its 
     confidential use. Under no circumstances shall the 
     Institution, or any of its directors, officers, or employees, 
     disclose or make this document or any portion of it public in 
     any manner.
       If a subpoena or other legal process is received calling 
     for production of this document, the District Director--
     Examinations should be notified immediately. The attorney at 
     whose instance the process was issued, and, if necessary, the 
     court which issued the process, should be advised of the 
     above prohibition, and referred to Part 505 of the General 
     Regulations of the Federal Home Loan Bank Board.
       Directors, in keeping with their responsibilities, should 
     review this report thoroughly. This report should not be 
     considered an audit report.

                                Comments

       Information concerning the Institution's policies, 
     practices and condition, considered to be of supervisory 
     interest or concern, is shown below.
       A. Objectionable Conflicts of Interest
       Conflicts of interest involving James McDougal, Susan 
     McDougal, and William Henley have been detrimental to the 
     safety and soundness of the Institution. These individuals 
     are in control of the Institution (Madison Guaranty) through 
     their stock ownership. James McDougal owns 63.5% of the 
     outstanding Madison shares. His wife, Susan McDougal, owns 
     12.6%, and her brother, William Henley owns 8.5%. In addition 
     to his ownership control, Mr. McDougal, as President of the 
     Institution's subsidiary (Madison Financial), has complete 
     control of the land development projects discussed in comment 
     B.
       This control enabled Mr. McDougal to structure the 
     development and financing of the projects so that substantial 
     cash payments could be diverted to himself, Susan McDougal, 
     William Henley and others. These payments have directly 
     benefited these individuals, but Madison Guaranty has 
     received little or nothing in return. Though they have been 
     structured to avoid specific Insurance Regulations, these 
     payments are contrary to the general policy of the FHLBB 
     concerning conflicts of interest as stated in Insurance 
     Regulation 571.7 and FHLBB Memorandum R-19a.
       Many of these payments have been funneled through business 
     entities which are owned or controlled by the McDougals, 
     employees, relatives of employees, or close friends of the 
     McDouglas and Henley. In the report, reference will be made 
     to these individuals as the McDougal-Henley Group. Though the 
     activities of these business entities may be appropriate for 
     a savings and loan institution to perform, the advantages 
     associated with these activities accrue to the McDougals and 
     Henley, rather than Madison Guaranty. As such, these 
     arrangements are contrary to the FHLBB's policy concerning 
     appropriations of corporate opportunity as explained by 
     Insurance Regulation 571.9.
       Mr. McDougal stated that there were no violations of the 
     conflict of interest regulations.
       There are several of these business entities, none of which 
     are disclosed on the Examination Management Questionnaire. 
     The investigation of these businesses remains incomplete. For 
     example, the amount of Madison Guaranty loan proceeds going 
     to many of the entities is unknown. Formal investigative 
     powers have been granted; in this case, under Section 
     407(m)(2) of the National Housing Act. Current findings, with 
     respect to three of the more important business entities, are 
     discussed below.
       1. Madison Real Estate
       Madison Financial pays commissions to Madison Real Estate 
     for selling land from Madison Financial's developments. These 
     commissions in turn are distributed to the sales personnel. 
     Mr. Latham stated that Madison Real Estate was ``a division'' 
     of Madison Financial. Mr. McDougal stated that Madison Real 
     Estate was essentially formed in order to use Susan 
     McDougal's real estate sales license which, in turn, was 
     being used by Madison Financial to market the projects. But 
     Madison Real Estate's checking account was not on Madison 
     Financial's books until after management was notified of this 
     fact by the examiners. Also, Madison Real estate is not 
     registered in county records as a name being used by Madison 
     Financial or anyone else.
       Since the beginning of 1983, after the McDougals and Henley 
     acquired Madison Guaranty, substantial commissions were paid 
     through Madison Real Estate to William Henley ($427,683) and 
     Susan McDougal ($137,500). In Henley's case, a substantial 
     portion of these funds were advances against commissions to 
     be earned on future land sales. Other McDougal-Henley Group 
     members, who received substantial commissions, are Pat Harris 
     ($242,289) and James Henley ($154,690), who is the brother of 
     Susan McDougal and William Henley. These payments represent 
     most of the commissions paid by Madison Financial to 
     Madison Real Estate, which significantly derives all of 
     its business from Madison Financial
       Many of the sales, which generated these commissions, were 
     to McDougal-Henley Group members who are acting as straw 
     buyers. Madison Guaranty essentially retained the risks of 
     ownership on these transactions because it fully financed 
     these sales including the cash sales commissions. Thus, 
     Madison Guaranty's position deteriorated because it retained 
     the same ownership risks as before, but paid cash fees to 
     these individuals. In addition, fees paid through Madison 
     Real Estate were used as down payments in some of the straw 
     land purchases in an apparent attempt to disguise 100% 
     funding of the purchase by Madison Guaranty and its 
     subsidiaries.
       Messrs. McDougal and Latham cited an April 24, 1985 letter 
     from a Federal Home Loan Bank of Dallas Supervisory Agent as 
     permission to pay real estate sales commissions to Madison 
     Real Estate. However, this letter in part, asks that the 
     Board of Directors review Insurance Regulation 571.7 which is 
     cited above in this comment.
       2. Madison Marketing.
       Madison Marketing is paid for doing all the general 
     advertising for Madison Guaranty and most of the advertising 
     for Madison Financial's land development projects. All of 
     Madison Marketing's business is derived from Madison Guaranty 
     or its subsidiaries. Since 1983 these payments total 
     $1,532,000. Until February 1986, Susan McDougal owned Madison 
     Marketing. During a portion of this time, it was a 
     corporation which was incorporated by Lisa Aunspaugh, 
     reportedly a close friend of Susan McDougal.
       Mr. Latham stated that after February 1986, Madison 
     Marketing became an entity ``d/b/a (doing business as)'' for 
     Madison Financial and ceased to be a corporation. However, it 
     is not registered as a ``d/b/a'' in the County records. Also, 
     its checking account has never been recorded on the books of 
     Madison Financial.
       Given the evidence of Madison Marketing's invoices, it is 
     questionable how much of these advertising services are 
     actually performed by the firm. The actual work of 
     advertising, such as the design and production of commercials 
     and providing air time or newspaper space, appears to be 
     performed by others. Madison Marketing apparently just pays 
     the bills of other providers and adds a 15% fee of its own. 
     Examiners estimated this fee to be approximately $200,000 
     since 1983. It would appear that Madison Guaranty could have 
     an employee perform similar work for much less money.
       Mr. Latham stated that Madison Marketing made no payments 
     to any stockholders. This statement is false. As a part of a 
     test for such payments, the examiners discovered two 
     remittances from Madison Marketing to Susan McDougal which 
     total $50,000. This was a text, and there may be additional 
     payments.
       3. Designer's Construction
       Designer's Construction performs construction work on some 
     of the land development projects and on some of the property 
     securing Madison Guaranty loans. In 1985 and to date in 1986, 
     $247,000 was paid for work performed for Madison Guaranty and 
     its subsidiaries. The amount of loan proceeds paid to 
     Designer's Construction on work for third party borrowers is 
     unknown.

                          ____________________