No Smoking Gun. In my April 4th letter on Whitewater, I wrote that members of the Board of Directors of Silverado Savings and Loan had contributed to the 1988 presidential campaign of George Bush and that they had done this while the savings and loan was being investigated by federal regulators. Although both of these allegations are probably true, there is no "smoking gun" information in hand to make the case. I have no hard evidence a federal investigation was going on during the 1988 campaign and only the memory of a Frontline program to support the contention Silverado board members contributed to the Bush campaign. Because of this, I subsequently wrote that both of these assertions needed to be checked for accuracy in the event they were covered in your paper. My guess is that a few minutes on the phone to your news sources in Denver would give you information I would need weeks or months to get.

Four Distinct Types of Criminal Acts. I have closely read all of the news accounts on Whitewater, including the April 2 hit piece on the criminal referrals to Madison Guaranty that you printed on your front page. As you or any other reader of the article knows, the referrals were leaked to the Washington Post by an anonymous source. If I were a betting person, I would say that the source most probably is in the Resolution Trust Corporation (RTC). [I was right, it was L.Jean Lewis.] I appreciated the article because it led me to reflect on the actual or alleged criminal acts that have occurred in the S&Ls since 1982, and in particular, those that involve political contributions. I see a pattern in what has been alleged about Madison, in what I suspect about Silverado, and what clearly seems to be true of Lincoln Savings and Loan (see below -[the second part of the letter is on another web page). The pattern suggests that four distinct types of criminal acts may have been committed.

First, money was "skimmed" (in Congressman Leach's words) from a savings and loan for political contributions.

Second, the money went to help elect a man to a high political office; the person in that office having the power to appoint people to regulate savings and loan associations.

Third, at the time the money was contributed, the savings and loan was under investigation by federal regulators who had access to the association's financial records. All things considered, it would have been difficult, if not impossible for the savings and loan to conceal this mis-application of funds at the time it occurred. There seems to be two possibilities: One, the regulators were not competent enough to detect the skimming of funds and that therefore the regulators comitted no criminal act. Two, the regulators chose to ignore the indications of political payoffs and to follow up possible leads. If true, this would amount to an obstruction of justice at the field investigative level, at the regulatory agency level, or both.

Fourth, if a regulatory agency knowingly investigated some savings and loans while ignoring direct indications of similar criminal allegations against other savings and loans, then the realm of political corruption and a criminal conspiracy has been entered.