PayThink

The theme of many Dodd-Frank two-year anniversary articles this summer was all about how many rules required by the legislation were still up in the air. That might be about to change.

Every consumer should have access to a low-cost, full service bank account that helps them make necessary payments, manage cash flow and avoid ancillary fees.

A simpler calculation isn't necessarily the right one. If a capital ratio misrepresents a bank's risk or creates incentives to take on more of it, simple is scarcely an improvement.

While deposit-driven financial institutions, at best, could use small-dollar loans to bring in customers who would later purchase other products, installment lenders have been successfully serving underserved communities for close to 100 years.

We can only speculate about the real purpose for the Volcker Rule.

Adopting universal terminology will allow financial institutions to quickly identify, understand and share information about threats, plan for different scenarios and build the systems required to effectively defend their interests.

The board of directors must anticipate the unexpected and quickly execute strategic alternatives when a problem arises, regardless of its severity. Failure to do so could land their financial institution on the FDIC's problem list.

"The 20% down payment is not part of our proposal," said Consumer Financial Protection Bureau Director Richard Cordray, in Senate testimony, about the qualified mortgage rule.

Fanatical insistence on lending to risky borrowers to get them to buy more houses destroyed trillions of dollars. Now there's pressure to make even riskier, unsecured loans to these consumers. A freer, fairer market would do better.

The Consumer Financial Protection Bureau has, as required by Dodd-Frank, appointed members to a board that will consult twice a year with director Richard Cordray. The members range from bank executives to consumer advocates.