Dodd Frank was bad enough of an overreaction to the crash, butthe follow on has been far worse and is now damaging the economy.First we had the Obama Holder personal vendetta against Jamie Dimonto punish him for actually having the temerity to speak the truthpublicly instead of towing the administration party line. That $20billion personal attack has cost hundreds of good jobs at JPM, andwill continue to restrain hiring and spending by the bank forseveral years. Who lost- the lower and mid level people who got cutor never got hired. As important the economy suffered as that wascapital which could have gone to capital and been used to makeloans to all of you. The same has been done to B of A, and others.While JPM and B of A made some mistakes, none of it was criminal,and punishing the economy and lower level workers accomplishednothing good. Nobody seems to have held the bond buyers accountablefor not doing their due diligence and buying the junk withoutthinking or working.

Now we have the real issue for all of us. The follow on toall of this is the avalanche of regulatory burden that has befallenall of the major banks. Even though it will never stop a crookedindividual from trying to beat the system, the banks are now tiedin knots with paperwork and compliance rules that are causing thesystem to become dysfunctional. Talk to almost any banker today andyou will hear that the paperwork burden is killing them, and theycan't be bankers serving their clients like they want to be becausethe regulatory burden is so crushing. Whether it is line bankers atretail, private bankers who now must sign documents saying theirclients have been investigated and are not money launderers or drugdealers, or commercial real estate lenders, they all have to do somuch know your customer and follow on work that they have no timeto do banker work serving clients. The result is there are now alot of very angry and frustrated bankers at all levels who want tomake loans and do the other things that bankers do, but they spendso much time on regulatory work they hate it now. All whilebudgets are cut to have the capital to pay over to Holder so he andObama can tout to Elizabeth Warren and her coterie, that they arereally going after the greedy bankers. May make good short termpolitics but in the end it is terrible politics because it coststhousands of jobs in all the banks and causes lending to bematerially curtailed. Capital that would otherwise have been thereto back stop the bank balance sheets has been paid to theadministration to help close the deficit loophole along with theillegal payments of dividends from Fannie and Freddie instead of toshareholders. So the government gets billions, and borrowers get noloans and reduced service.

For CRE it is a growing problem. Home mortgages remain hard toget and now the housing market is in a swoon of sorts. This willnot change for quite awhile. This will damage not only the homebuilders, but all of the related businesses that spin off that. ForCRE it means restraints on lending and CMBS, even though thatmarket has returned fairly well recently.

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Joel Ross

Joel Ross began his career in Wall St as an investment banker in 1965, handling corporate advisory matters for a variety of clients. During the seventies he was CEO of North American operations for a UK based conglomerate, and sat on the parent company board. In 1981, he began his own firm handling leveraged buyouts, investment banking and real estate financing. In 1984 Ross began providing investment banking services and arranging financing for real estate transactions with his own firm, Ross Properties, Inc. In 1993 Ross and a partner, Lexington Mortgage, created the first Wall St hotel CMBS program in conjunction with Nomura. They went on to develop a similar CMBS program for another major Wall St investment bank and for five leading hotel companies. Lexington, in partnership with Mr. Ross established a hotel mortgage bank table funded by an investment bank, and making all CMBS hotel loans on their behalf. In 1999 he formed Citadel Realty Advisors as a successor to Ross Properties Corp., focusing on real estate investment banking in the US, UK and Paris. He has closed over $3.0 billion of financings for office, hotel, retail, land and multifamily projects. Ross is also a founder of Market Street Investors, a brownfield land development company, and has been involved in the acquisition of notes on defaulted loans and various REO assets in conjunction with several major investors. Ross was an adjunct professor in the graduate program at the NYU Hotel School. He is a member of Urban Land Institute and was a member of the leadership of his ULI council. In 1999, he conceived and co-authored with PricewaterhouseCoopers, the Hotel Mortgage Performance Report, a major study of hotel mortgage default rates.