Mr. Dudley notes that the profitability of banks has dropped in light of their reduced leverage, but he asserts that they remain "profitable enough to cover their cost of capital." What makes this remark particularly notable is the  who claimed that (i) banks' return on equity was low because they were too highly leveraged (a completely counterintuitive assertion that Mr. Hoenig did not fully explain) and (ii) that banks were less profitable than essentially every other industry (…

Many critics argued that conflicts mineral disclosure was an unworkable idea when the requirement was originally adopted as part of Dodd-Frank. Few predicted that the requirement could attain this degree of uselessness. Time for a repeal?

CHOICE Act Section 391 requires that various federal agencies (which are enumerated in Section 311 of the bill, but essentially includes the major U.S. financial regulators) better coordinate among themselves which agency should be the lead in any regulatory action where numerous agencies are involved. It does not, by its terms, impose any obligations on state regulators; it merely requires that the federal government act as a unified entity (which would seem entirely sensible, would…

Politically, these executive actions are promoted as being for the purpose of holding Wall Street accountable. The larger benefit they provide is to put a check on the very broad discretionary powers afforded the government under Dodd-Frank. These executive actions move financial regulation back toward a system of rules governed by written procedures and not by grants of broad discretion.