We understand this poses a challenge for industry, just as the writing of such a substantial set of mortgage rules by last January posed a significant challenge for our new agency. Had we failed to do so, many key statutory provisions that Congress had enacted in Title XIV of the Dodd-Frank Act would have taken effect in their own right, which everyone recognizes would have been much harder on industry and much worse for the mortgage market.
I know hating on Congress is the new hotness, but they do write laws, not helpful suggestions that regulators then work with the industry they regulate to shape into something less "challenging."
With Lehman +5 approaching, there's no better representation of the mindshare corruption that made our response to the meltdown so inadequate.