OTS officials have argued this is a mischaracterization since other struggling banks, such as Wachovia, Citigroup ( C ) and Bank of America ( BAC ) could easily have failed without regulatory intervention, but were protected because they were seen as more systemically important. In 2009, the Obama Administration prosed the OTS be merged into the OCC as part of a larger financial reform package. Spokesmen for the OCC and the OTS both rejected the notion that OTS officials are getting tough to protect their careers. Bill Ruberry, the OTS spokesman, says enforcement orders and other regulatory actions go through multiple layers of approval, so an effort by OTS officials to save their jobs by getting tough would require "some kind of grand conspiracy." Ruberry also rejects the notion that the OTS has become tougher since the crisis, arguing that enforcement actions are up and exam ratings are down "because the health of the industry has declined."