Dodd-Frank Remains a Troubled Work in Progress

Dodd-Frank will go down in history the financial industry equivalent of the Dred Scott decision. It should have been named the "We'll Torture Bankers and Take Their Money Whenever We Please Act."

The time has arrived for a serious evaluation of what in DFA is working and what is not. It is no criticism of the advocates of the legislation to suggest that there is room for reconsideration. That should be standard practice for any regulatory program as long as human judgment and foresight remain limited. This important book, the work of the Bipartisan Policy Center, and others who are serious about good and effective financial supervsion that actually makes things better should be part of that review.

Good and useful piece. Definitely not addressing housing policy in the US was a significant element left out. TBTF is very much still a problem especially when leverage and liquidity rules are watered down or not enforced. However, it is important to point out a number of other points. Dodd-Frank remains a 'troubled work in progress' because of tremendous lobbying against every component of the law. Secondly, the SEC and CFTC especially are hamstrung by having budgets delayed and lessened. Also, Dodd-Frank does not create a 'regulatory system that suppresses market discipline in favor of regulatory expertise and broad regulatory authority.' Market discipline can only occur when there is transparency about banks' on- and off-balance sheet risks. Basel III Pillar III already exists with guidelines on this, but Pillar III is either not implemented yet as in the US or it is implemented and supervised unevenly as in Europe. Mayra Rodriguez Valladares

The attitude that every effort to make the provisions of DFA work better in practice is "tremendous lobbying against every component of the law" feeds the Washington paralysis that never fixes anything. It is time to set such attitudes aside and face DFA in a reasonable, bipartisan manner.