This week marks the end of the public comment period on the Volcker rule. The usual suspects have all delivered their comments. The huge finance lobby delivered their mass of comments, in particular calls for multiple exemptions and waivers. But a new group, Occupy the SEC, a collection of experts in finance which sprung out of the Occupy Wall Street movement, delivered a 325 page letter to the SEC about the rule reminding the SEC about their obligations to the public.

Miller’s core strengths were always consumer protection and financial regulation, not quite in the window of the major priorities for a Governor. Attorney General would be a great fit, but Democrat Roy Cooper (who’s on the foreclosure fraud settlement executive committee) will run for re-election.

Too failed to be big? Today, Public Citizen will send a formal petition to the Federal Reserve Board of Governors and the Financial Stability Oversight Council to break up Bank of America. The petition asks them to “recognize that the Bank of America Corporation . . . poses a ‘grave threat’ to the stability of the United States financial system and to mitigate that threat, as provided by section 121 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.”

NYT reporter Louise Story reports on a new investigation in New York of big banks and their mortgage practices. This one is not being run by Attorney General Eric Schneiderman, though he reserves the right to get involved. Instead, the New York Department of Financial Services is investigating the banks on the issue of forced-place mortgage insurance, one of the biggest bank scams going.

Jon Huntsman has always been able to get some media love, and it’s interesting how he’s using it in his last-ditch attempt to salvage his Presidential campaign. He’s going after Mitt Romney for being a servant to big banks and saying the TBTF banks need to be “right sized.”

If you needed to appeal to one authority on banking regulation, you could do worse than to consult Sheila Bair, the former chairwoman of the FDIC. And now she’s advocating scrapping the Volcker rule and starting over. She comes at this by looking at the spectacle of MF Global – a brokerage house that would not be covered under the Volcker rule – and asking whether they would be permitted to trade depositor funds on their own account if they were a bank. The answer is far less clear-cut than it should be – and that’s the problem with how the Volcker rule emerged from the sausage grinder of the regulatory apparatus.

Today, the Consumer Financial Protection Bureau unveiled a prototype credit card agreement designed to ease understanding of obligations. The CFPB will test the statement with the Pentagon Federal Credit Union, one of the largest in the nation. This comes just before a Senate vote on Richard Cordray’s nomination to head the CFPB.

Rep. Barney Frank plans to retire, which means by next year, both lead co-sponsors of Dodd-Frank will be out of Congress, having secured a legacy of sorts through attaching their names to that legislation. So who might replace Frank as ranking member or Chair of the House Financial Services Committee?

Sit down for this one. Because you’re just not going to believe it. It seems that the more credit rating agencies are paid by corporations and banks to rate their debt, the more favorable ratings they hand out! This goes against everything I know about the untainted, incorruptible hand of the free market, and comes very close to shaking my faith in the credibility of the rating agencies.

The finance lobby wants to weaken the Volker rule that limits proprietary bets by regular banks. They find the weakest link in the regulatory chain and ride that link to achieve their ends. And the weakest link is usually the Office of the Comptroller of the Currency, colloquially known as the Office of Bank Advocacy.