Eugene A. Ludwig
Chairman

Eugene A. Ludwig is Chairman of the Board of Promontory Asset Finance Company, and Founder and Chief Executive Officer of Promontory Financial Group, a financial services organization that invests in, advises, and creates financial products for financial services organizations.

Prior to founding Promontory, Mr. Ludwig was Vice Chairman and Senior Control Officer of Bankers Trust/Deutsche Bank. He joined Bankers Trust in 1998, and was a member of the firm’s Management Committee, Chairman of the Control Committee and Co-Chairman of the Capital Commitment Committee.

Earlier, Mr. Ludwig served for five years as Comptroller of the Currency of the United States. As Comptroller, Mr. Ludwig headed the Office of the Comptroller of the Currency (OCC), the federal agency responsible for supervising the preponderance of bank assets in the United States.

During his tenure as Comptroller, Mr. Ludwig also was Chairman of the Federal Financial Institutions Examination Council, revitalizing the work of the President’s Working Group on Financial Markets. He served as Chairman of the interagency Federal Consumer Electronic Payments Task Force, a Director of the Federal Deposit Insurance Corporation, a member of the Basel Committee on Banking Supervision, and Chairman of the Neighborhood Housing Services.

Mr. Ludwig led the OCC during a period of substantial change – both within the financial marketplace as well as in the supervisory and examination practices of the agency. He is credited with improving the safety and soundness supervision of the banking industry and developing a “supervision by risk” approach to bank supervision that has been adopted by leading regulators worldwide.

At the same time, Mr. Ludwig spearheaded efforts to reform the Community Reinvestment Act and vigorously enforce the fair lending laws that resulted in a fourfold increase in financing for America’s low- and moderate-income communities.

Prior to being Comptroller, Mr. Ludwig was a partner in the law firm of Covington & Burling in Washington, specializing in banking law.

He has written numerous articles on banking and finance for scholarly journals and publications and has been a guest lecturer at Yale and Harvard law schools and Georgetown University’s International Law Institute.

A native of York, Pennsylvania, he graduated magna cum laude from Haverford College and received a scholarship to Oxford University, where he earned a Bachelor of Arts degree and a Masters of Arts degree as a Keasbey Fellow. He holds a LLB from Yale University where he was editor of the Yale Law Journal and chairman of Yale Legislative Services.

John A. Costa
Chief Executive Officer

Mr. Costa is Chief Executive Officer of Promontory Asset Finance Company. He joined Promontory from ING, where he was Head of the Securitization Group in the Americas. Mr. Costa managed a team that generated $30 million in revenue in 2002. He has experience in a variety of asset types, including credit cards, auto loans, non-prime credit cards, land loans and other unusual asset classes. He sourced M&A opportunities in specialty finance companies, and designed an unusual credit enhancement technique to provide liquidity support to commercial paper conduits utilizing structured liquidity notes (SLNs).

Prior to ING, Mr. Costa served as an outside director at Litchfield Financial Corp, a publicly held finance company. After four years as a Director, he became an Executive Vice President in March 1999, with major responsibility for developing alternative funding strategies and directing asset securitization and conduit development. He was a member of the credit committee, was a key participant in strategic decisions, and served as member of the Board's Audit Committee, Stock Option Committee and Compensation Committee.

Earlier, Mr. Costa was a Senior Vice President and Limited Partner at Cardholder Management Services. He acquired an industrial loan corporation charter (now called Merrick Bank) in order to become a credit card issuer. He subsequently assisted in the acquisition and sale of credit card portfolios.

Mr. Costa has held several positions on Wall Street: Director of Consumer Finance at US West Financial Corporation; Managing Director for Arsht & Company, Inc. a boutique M&A firm in NYC; Vice President, Manufacturers Hanover Securities Corporation, section 13 subsidiary of Manufacturers Hanover Trust; EF Hutton, 1985-1989, Assistant Vice President for Hutton Indemnity Corporation. He holds a B.A. from New York University, where he graduated magna cum laude. He is Series 7, 24 & 63 licensed.