"ABA supports comprehensive reform, but not this reform," says Edward Yingling, president and CEO of the American Bankers Association. According to Yingling -- whose group represents all of the major financial firms, including Bank of America ( BAC), JPMorgan Chase ( JPM), Wells Fargo ( WFC), Citigroup ( C), Goldman Sachs ( GS), and Morgan Stanley ( MS) -- the proposed reform would create additional conflicts between state and federal regulators, unnecessarily increase the cost of doing business and restrict available credit for consumers and businesses in need of loans. The ABA would prefer to add a systemic risk regulator, come up with a solution for "too big to fail" entities, and strengthen consumer protection measures within the existing framework. The bank lobby also points out, importantly, that while the Dodd plan would perhaps simplify federal banking oversight, it wouldn't address the issue of conflict between state and federal banking authorities. It may add confusion from a banker's point of view, but it also leaves opportunity for banks to go "regulator shopping" for the agency most friendly to their goals. "It doesn't eliminate regulatory arbitrage -- let's be realistic about that," says Kevin Petrasic, a lawyer for financial companies at the law firm Paul Hastings, and former special counsel at the Office of Thrift Supervision. The OTS, along with the Office of the Comptroller of the Currency, would be rolled into FIRA. The federal regulator would also usurp the supervisory powers of the Fed and the FDIC, though the FDIC would still operate as an insurance fund for state-chartered banks. In response to criticism of Dodd's proposal, consumer advocates have dug in their heels for a fight: "We intend to ... strengthen lawmakers' bills and fend off pernicious special interest amendments to weaken or delay final passage," said Ed Mierzwinski, director of consumer programs at U.S. PIRG, the federation of state Public Interest Research Groups.