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Doomed by complexity?

By Marcie Geffner · Bankrate.com
Monday, December 6, 2010
Posted: 3 pm ET

The federal Dodd-Frank Wall Street Reform and Consumer Protection Act is so complicated that the American Bankers Association, or ABA, has created a separate website, the ABA Dodd-Frank Tracker, for the exclusive purpose of tracking the implementation of the act's numerous components and archiving the group's involvement in what promises to be a long process.

The website is billed as a resource for both ABA member banks and the public, but it's probably of greater interest -- and rightfully so -- to the group's membership than the average U.S. consumer. That's not to say consumers don't have a stake in the issues or the intelligence to understand them, but rather that much of the information is no doubt likely to have something of an ABA spin and something of a targeting toward the group's member banks. That's only to be expected from a project that's run and funded by an industry trade group.

That said, the tracker is an impressive effort. There are separate sections for Mortgage Finance, Interchange, Deposit Insurance, Systemic Risk, Preemption, Supervision and Oversight, OCC-OTS Merger, Prudential Supervision, Building the Bureau, and Capital. Also on offer are a Topics List, Executive Summary, Summary by Title, Summary by Table of Contents, Full Text, Implementation Overview, Master Calendar, Effective Dates, Ruling Making Dates and more.

A savvy tax expert once pointed out to me that the federal tax code couldn't have achieved its current levels of complexity were it not for the aid of tax software. That seems a strange notion, but it fact, it makes sense. Without the technology, we couldn't have a tax code that's as complicated as ours is.

The Dodd-Frank Tracker, not to take a poke at it per se, seems to hint at a similar issue. We wouldn't be able to have a law that's so large and complicated were it not for the technology that allows us to draft, create and, yes, track it.

The obvious question: Might our framework of society be in danger of collapse simply because our laws have become so complicated, thanks in no small measure to technology, that no one can understand what the laws actually require?

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