Editor's note: A version of this post originally appeared on LinkedIn.
The Dodd-Frank Act of 2010 is a sprawling body of initiatives cooked atop the smoldering wreckage of the financial crisis. Some were decades late. Others are at best half-baked.
One that might include a bit of both elements is the so-called Financial Stability Oversight Council. Explains FSOC's website:
"Established under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Council provides, for the first time, comprehensive monitoring of the stability of our nation's financial system. The Council is charged with identifying risks to the financial stability of the United States; promoting market discipline; and responding to emerging risks to the stability of the United States' financial system."
Who, you might ask, is providing the comprehensive monitoring of the stability of our financial system? That would be 15 A-list U.S. financial regulators: the Treasury secretary, Federal Reserve chair, Comptroller of the Currency, head of the Federal Deposit Insurance Corp. and so on. In other words, the same folks who were at the table before and during the last financial crisis.
Just how confused policymakers were at the height of the crisis got fleshed out on Friday with the release of transcripts of the 2008 meetings of the Federal Reserve's policy-setting Federal Open Market Committee. The transcripts, chronicled by a very cool New York Times interactive timeline, show flashes of insight. Lots of cluelessness, too. Like when the FOMC met on Aug. 5, 2008, and, more fearful of inflation than insolvency, held rates steady. Over the next two weeks, Fannie Mae, Freddie Mac and Lehman Brothers all failed.
Poor communication among government regulators may have contributed to the crisis. There's no question that the lack of a legal framework for dealing with the fast-unfolding events left those in charge playing a game of policymaking whack-a-mole.
Efforts to ensure that we're better prepared next time around are laudable. So are efforts by the FSOC and anyone else that raise warning flags in advance about possible areas of vulnerability, like money market funds and wholesale lending.
What gives me the heebie-jeebies is the hubris implicit in the notion that next time around a legislatively mandated assemblage of great minds will prove more prescient than our leaders were last time. Yet FSOC's mandate seems to imply that it will somehow create a more transparent crystal ball.
Supposedly helping in that mission is another Dodd-Frank offshoot known as the Office of Financial Research. OFR's mandate: "To improve the quality of financial data available to policymakers and to facilitate more robust and sophisticated analysis of the financial system."
Even if you buy the notion that more sophisticated data will enable policymakers to foretell the next crisis, it's worth noting that critics see the OFR as already having become a political football that got punted inside the Treasury where its effectiveness will be muted. The Fed, meanwhile, didn't bother waiting to find out; instead it set up its own Office of Financial Stability and Policy Research.
Sticking with the gridiron analogy, the entire FSOC-OFR exercise reminds me of Charlie Brown hoping against hope this time will be different and that Lucy won't pull away the football at the last second. It's the same sort of false confidence that sends millions of people to Las Vegas every year.
Hope springs eternal. So do human folly and hubris. To me, it seems the lesson of the FOMC transcripts is not that more meetings and better research will enable us to see the next crash coming. Rather, it's that we should be fortifying our institutionsand making them small enough to failfor when it arrives.
Neil Weinberg is the editor-in-chief of American Banker. The views expressed are his own.