As a general rule, we believe that risk incidents concentrate policy-maker attention on long-simmering concerns in ways that lead to fast-breaking new requirements and heightened political and reputational risk across the financial sector.  Perhaps the most recent case in point is the pressure put on all large banks after Wells Fargo’s cross-selling scandal broke in 2017, but much in the body of industry law and rule results not from prolonged study of complex challenges, but instead from rapid efforts by regulators to allay Congressional scrutiny and by Congress to comfort constituents.

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