ANALYSIS : Is M. Danny Wall’s Job Necessary? : S&Ls;: As healthy thrifts become more like banks, many industry officials question whether it makes sense to have two separate regulatory agencies.

The resignation of M. Danny Wall as the country’s top thrift regulator has raised a bigger question: Is his job necessary?

The agency he resigned from Monday, the Office of Thrift Supervision, is less than four months old, having been created this summer as part of the savings and loan bailout signed by President Bush in August. Under Wall’s tenure, it has been a demoralized, embattled successor to the Federal Home Loan Bank Board, with considerably less responsibility.

Moreover, many thrifts are going out of business and the healthy survivors are becoming more like banks each day. As the line blurs between the two, many industry officials and former regulators are questioning whether it makes sense to have separate agencies. Why not, they ask, charge the same people who regulate banks with regulating savings and loans?

“I think it will be sooner rather than later. It seems logical,” said Edwin J. Gray, a Florida thrift executive who headed the bank board from 1983 to 1987.

The OTS, like the bank board before it, supervises thrifts and approves new applications.

Yet an important function, overseeing the deposit insurance system, was carved out of the agency and is administered by the Federal Deposit Insurance Corp., which historically only was responsible for the guarantee of bank funds on deposit. The OTS also is not the independent agency the bank board was, having to answer now to the Treasury Department.

In addition, the Federal Home Loan Mortgage Corp., or Freddie Mac, was under direct control of the bank board. Now Freddie Mac, which buys residential mortgages from lenders, answers to an independent board of directors.

Many believe that the system would be much simpler if the regulatory systems were combined, possibly by merging the OTS with the Office of the Comptroller of the Currency, which regulates national banks and also is part of the Treasury Department.

“It’s a very convoluted system at this time. The complexity of it is unworkable to begin with,” said Richard T. Pratt, another former bank board chairman who now is an executive with Merrill Lynch & Co.

The savings and loan industry, through the U.S. League of Savings Institutions trade group, has taken no official position on whether the OTS should be scrapped. But rumblings have started for a good many reasons.

One main one is that thrifts will pay the agency’s $298-million annual budget through hefty fees. About $140 million is expected to come from fees for examinations and applications, with the rest coming from assessments based on asset size of each institution.

In addition, thrift executives have been concerned in recent weeks that the OTS will overreact to past criticism that regulators have been too lax by becoming too tough.

Finally, banking regulators are becoming more involved in regulating thrifts anyway. The FDIC insures and examines thrifts now. And its chairman, L. William Seidman, is overseeing the mopping up of the thrift fiasco as chairman of the Resolution Trust Corp., a new agency created to manage the assets of the nation’s failed thrifts.

Wall, who took over as head of the bank board in July, 1987, has been criticized for downplaying the severity of the nation’s savings and loan mess and causing losses to mount as a result. Although thrift officials say the issue of whether the OTS should exist would have surfaced anyway, no doubt Wall’s problems and the publicity surrounding them have helped focus attention on the question.

“The real problem is in the system and its structure, and that doesn’t go away with Wall’s resignation. OTS is an unneeded agency,” said Bert Ely, an Alexandria, Va., thrift industry consultant.