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Even where Dodd-Frank gets it right, the implementation has lagged. Perhaps the most important new position called for by Dodd-Frank, the "Vice Chairman for Supervision," remains unfilled three years after the bill was passed. This key position has responsibility for supervising banks, particularly the systemically-important "too big to fail" banks. The job needs to be filled, and the function needs to properly staffed and budgeted to do its vital work.

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