In a recent report, the Government Accountability Office noted some troubling trends in Dodd-Frank implementation. First, regulators are not consistently employing "key elements" of regulatory analysis. Because most of the federal financial regulators are independent regulatory agencies, they are not legally required to follow those standards, but as a matter of good government, they ought to follow them. Second, most financial regulators "continue to lack formal policies and procedures to guide interagency coordination," which GAO had recommended in a prior report. Coordination of the intertwined and overlapping Dodd-Frank rulemakings is vital to minimize problems for investors, consumers, and the economy as a whole.

The careless manner in which Dodd-Frank is being implemented matches the careless manner in which the statute was created. The statute was cobbled together before legislators had a clear understanding of the problems they were trying to solve. Much-trumpeted hopes about the law's efficacy masked the law's deep problems. In a book released today, I and my co-authors take a closer look at Dodd-Frank and suggest that the law is not a set of promising solutions, but a source of dangerous new problems.