A few years ago a fast food chain ran a terrific ad campaign touting its burgers. A little old lady stood in front of the counter in a competitor's store looking at an enormous bun housing a waif of a burger and growled, "Where's the beef?"

That refrain rings in my head every time I think about the SEC's campaign to regulate banks' loan-loss reserves. The SEC contends that banks are using their loan-loss reserves as "cookie jars" to store earnings during good times so they might be used to cover losses in bad times.

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