Bankstocks.com's Tom Brown took some heat from readers recently for calling President Obama's regulatory reform proposals "asinine" without offering any constructive ideas of his own. So a few days later he responded with a 10-point proposal that struck us as pretty sensible but, sadly, won't get much consideration in the halls of Congress.

Among his ideas: Consolidate banking regulators into a single agency; get rid of Fannie Mae and Freddie Mac; establish loan-loss reserve levels by loan type; reiterate the primacy of the three key capital ratios; trade credit-default swaps on an exchange and - community bankers will love this one - tax credit unions.

Some of these - the single regulator, the credit union tax - are, for purely political reasons, nonstarters. But others have merit and, if Washington is serious about getting credit flowing again, they should be looked at.

Take capital ratios. Officially, to be well capitalized, a bank must maintain a Tier 1 risk-based capital ratio of at least 6 percent and a total risk-based capital ratio of at least 10 percent. But, as Brown points out, regulators have their own "whisper numbers," and are requiring large banks to maintain Tier 1 ratios of 10 percent. "The single biggest impediment to credit intermediation today," Brown writes, "is the uncertainty the administration has created regarding which numbers count and how high they are supposed to be."

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