Chris Dodd has put his regulatory reform bill on the table. Bottom line: it is, at best, average--and certainly does not do what needs to be done to remake the rules of the economy.

    The biggest flaw, in my opinion, is giving the Federal Reserve Board more power, particularly placing consumer protection in the hands of the Fed--rather than in the hands of an independent Consumer Financial Protection Agency, a proposal that the Administration had laid on the table that I thought was a very good idea. It simply is not conceivable to me that the Fed will be a serious place for the defense of consumers' rights. After all, it's the Fed that was asleep at the wheel as the seeds of the financial crisis were sown--by the very circle that has enormous influence with the Fed, either by literally having people who sit on the Fed's governing board, or its regional banks, or by simply having the ear of those people who run the Fed.

    When was the last time someone you knew had the ability to influence the Fed?

   Second issue: while the Fed would oversee with more authority institutions with more than $50 billion in assets and have the power to seize and break up failing insitutions, the legislation does not do what I believe needs to be done--take a part the basic model of big banks and replace our banking system with regional and community banks. The big bank model is a failure because bankers of the Citibank philosophy (read: Robert Rubin) will be less attuned to the average person down the street than they are to the market and monetary manipulations that happen half way around the world.

    The Dodd bill only modestly addresses the core problems in our financial system.