Although the Dodd-Frank Act has many enemies, it has more to fear from its friends. Increasing evidence reveals federal financial regulators implementing it with only an equivocal and faint-hearted zeal. Outright repeal by Congress remains unlikely, but regulatory subversion may leave Dodd-Frank a hollowed-out shell.

Dodd-Frank’s structure rests on three distinct and plausible premises about the causes of the 2008 financial meltdown: