Congress wrote the law, and drew the details to such a fine point that FRB really doesn't have much discretion in the regulation. Congress, you needn't be reminded, is a political institution. It is very sensitive to public (read:consumer) opinion.
I don't hold out much hope that any appeal to the sensibilities of poliiticians will overcome their inherent desire to be reelected.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8