The other day up in New York, C. Todd Conover, one of the government's bank regulators, said in a speech before the Women's Bond Club that the nation's banking system "is fundamentally sound although weakened" by the number of failures and near-failures this year.

Fundamentally sound! Shades of Herbert Hoover, and of J. P. Morgan's soothing words at the time of the 1929 Wall Street crash that "my son and I are buying sound common stocks."

Conover is comptroller of the currency, the agency that shares bank regulatory functions with the Federal Reserve System and the Federal Deposit Insurance Corp. He said that 76 banks had failed through mid-December, compared with 48 in 1983 and 42 in 1982, reflecting the recessions of 1980 and 1981-82.

Conover -- he later announced that he plans to resign in a few months -- stressed that this was an extremely small percentage of the total number of banks in the country, and that since 1982, more new banks have been chartered than had failed.

But the public is not likely to take much confidence from an assessment that describes the system as "weakened," when bankers themselves confess their vulnerabilities: They have gotten way out on a limb in loans to Third World countries, and for energy development in this country. Crude oil prices are crumbling. And Conover himself cautioned that "the next big problem is going to be agriculture, and it's going to impact a lot of banks. Look for agriculture to create a lot of discussion in 1985."

According to an October 1984 survey by The American Banker, the industry trade paper 'bible,' one-third of individuals polled said they had less confidence in banks than they did "a few years ago." And money market managers are said to be withdrawing deposits from big banks that are exposed to potentially large foreign loan losses.

On top of that, there has been Conover's mania for deregulation: Since Nov. 1, 1984, he has approved 108 "nonbank banks," many of them owned by securities firms and insurance companies. Beyond that, he has tried to get Congress to expand legislative authority for banks to get into the insurance, securities and real estate businesses.

The comptroller doesn't think that enticing nonbanks into banking services, and banks into nonbanking businesses, will weaken the system. Today's problems, he told the women's club, are the result of "lousy loans, not deregulation."

But deregulation itself, stimulating an undisciplined competition, can lead managers into risky ventures to make a buck. As a Wall Street Journal survey published on Dec. 31, 1984, suggests, a major part of the banking system's problems is that there are already "too many banks taking too many risks." How can more pseudo-banks solve the problem? Overall, commercial banks posted record losses of $8.4 billion last year.

The lesson of the past few years is that the bigger the bank, the bigger the problem. The huge money center banks are the ones that are the most heavily committed in Third World loans. (Conover himself said, "There are 115 banks with loans outstanding to Argentina. There aren't 115 bankers in the country who can find Argentina on a map.")

Now, 1984's steep decline in oil prices threatens to make mincemeat of bank investments -- mostly in the U.S. Southwest -- for new energy development.

Moreover, William Cline's in-depth study for the Institute of International Economics claims that the adverse effect of sharply lower oil prices on the exporting countries' debt more than outweighs the beneficial effects for oil importers. (Mexico is a good example of where it will hurt the most.)

Oil prices have only one way to go -- down: OPEC is in a state of near-disintegration. "We are sick and dying," Saudi oil minister Sheik Yamani is reported to have said to a closed-door cartel summit last month in Geneva. With a buyers' market at hand, no one is building inventories. The United States Government is even considering suspending -- for budgetary reasons -- further purchases for its Strategic Petroleum Reserve stockpile.

Great Britain this week dealt yet another body blow to OPEC by junking official prices and deciding to sell its crude oil at free-market prices, currently about $27, or $2 below the OPEC $29-per-barrel benchmark for Saudi light. So much for OPEC's pressure on Britain and Norway to cut production to help support the cartel's artificial price structure.

What it all means, as Washington consultant Philip Verleger points out, is that as oil prices retreat from the $29 benchmark that OPEC is vainly trying to preserve, there will be more pressure on the banking system. A $25 price -- perhaps lower -- within a few months is likely, most experts says. Even a $20 price, Verleger suggests, is not unreal -- but maybe not this year.

Nonetheless, the direction is clear: it helps explain the below-$300 price for gold. For with oil and other commodity prices low, and real economic growth in the world still far behind the pace of the 1960s, inflation should stay down, and gold as an anti-inflation hedge is unnecessary. But for banks and others engaged in energy extravaganzas based on an inflated price of oil, and for Third World countries such as Mexico, it's big trouble ahead.