The U.S. Comptroller of the Currency and the Maryland banking commissioner yesterday raised new roadblocks to a group of Middle Eastern investors who plan to form a bank holding company to buy Financial General Bankshares Inc. Of Washington.

Maryland officials said the takeover attempt may violate the state's banking laws, which do not address the question of "unfriendly" acquisitions of banks.

Demanding additional information about the finances and backgrounds of the Middle Eastern investors, the comptroller's office warned that the group's plans for the Financial General banks could cause problems for the banks.

The comptroller questioned five separate aspects of the bank holding company plan, warning that "absent a satisfactory response from the applications... we would not recommend approval" of the plan.

The federal bank regulatory agency made its case in a letter to the Federal Reserve Board, which is considering the application submitted by Credit and Commerce American Holdings to form a bank holding company.

The bank holding company application must be approved before the group can acquire control of Financial General.

On Tuesday, the Virginia commissioner of financial institutions recommended the Federal Reserve reject the application.

Maryland banking commissioner W. Holden Gibbs said yesterday he is holding up his recommendation on the plan until the state attorney general rules on its legality. That ruling is expected later this week.

Gibbs, who spent 20 years as a bank holding company executive before taking the state post, said he asked the attorney general to enter the case because Maryland's banking laws do not appear to make provisions for an "unfriendly" bank takeover.

The way the law is written, he explained, only a bank itself can initiate a merger application. Financial General is fighting the takeover and is not about to initiate any action favorable to the other side.

"Even if it (an unfriendly takeover) turns out to be legal, I'll probably have other questions that are unanswered," Gibbs added.

Under federal law, when state regulators object to a bank holding company plan, the Federal Reserve must hold public hearings on the application. Those hearings could take months, Financial General lawyers say, and any delays presumably would benefit Financial General's present management.

Financial General Chairman B. Francis Saul II and president G. William Middendorf II, have been trying to stop the takeover for 12 months, when Middle Eastern investors, aided by former budged director Bert Lance, bought about 22 percent of the stock in the company.

One of a handful of bank holding companies with banks in more than one state, Financial General owns Union First National Bank of Washington, First American Bank of Virginia, and American Bank of Maryland, and half a dozen smaller banks.

Some of the Financial General banks have a shortage of invested capital that could be made worse by the plans outined in the bank holding company application, the Cptroller of the Vurrency has warned the Federal Rwserve.

The application states that the Financial General banks have adequate capital and will not require additional funds from anyone taking them over.

"Our analysis of the capital needs of some of the national banks (in the Financial General system) is inconsistent with that view," the comptroller said. The Middle Eastern group plans to expand some of the banks, the comptroller nlotes, "such growth may tend to exacerbate exising capital shortfalls."

Asking whether the group would be willing to invest additional funds in the banks, the comptroller also called for detailed personal and financial information about the investors involved in the group.

Major investors include Sheik Kamal Adham, former head of security for Saudi Arabia, Faisal Saud al Fulaij, financial consultant to the royal family of Kuwait, and Prince Muhammed, son of the ruler of Abu Dhabi.

Other investors in the group are less well-known, and the comptroller says all owners of the proposed bank holding company should be forced to disclose all their business and personal financial dealings for the past five years.

The comptroller also recommended that the Securities and Exchange Commission be asked its views on the plan. The SEC already has cited the group for violating securities laws in