This post was co-written by David Min, Associate Director for Financial Markets Policy at the Center for American Progress Action Fund, and Pat Garofalo.

After months of intractable negotiations with Republicans that went nowhere, and growing impatience from Americans irate that regulatory reforms for Wall Street still had not been completed, Sen. Chris Dodd (D-CT) today introduced his latest financial reform bill. Consumer advocates are approaching the bill with caution, as the proposal lacks a stand-alone Consumer Financial Protection Agency (CFPA), such as was proposed by the Obama administration and passed by the House of Representatives.

The Dodd bill instead creates a Bureau of Consumer Protection inside of the Federal Reserve, which has been heavily criticized for its past regulatory failures and for a culture that is seen as apathetic or even antagonistic to the concerns of consumer protection. Much like West Berlin during the Cold War, the Dodd Bureau would be surrounded by a hostile culture, and the loss of even one element of its independence could cause its downfall.

So the key is whether the new Bureau will it be sufficiently empowered and isolated from that hostile culture to be effective. Longtime consumer protection advocate Elizabeth Warren has listed four criteria for an effective consumer financial protection regulator: 1) an independent director appointed by the President and confirmed by the Senate; 2) independent budget authority so it is not prone to the whims of the appropriation process; 3) independent rule-making authority; and 4) independent enforcement powers.

A close reading of the Dodd bill shows that his Bureau largely meets these tests (and, in fact, Warren has cautiously praised the new bill). Here is how Dodd’s Bureau compares to the CFPA included in the financial reform bill passed by the House last year and the Obama administration’s initial financial reform proposal.

Provision	Senate Bureau of Consumer Protection	House Consumer Financial Protection Agency	Administration Consumer Financial Protection Agency
Presidentially Appointed Director	Yes, confirmed by the Senate.	Yes, confirmed by the Senate.	Yes, confirmed by the Senate.
Independent source of funding	Yes, from the Federal Reserve Board budget.	Yes, from the Federal Reserve Board budget.	Yes, with fees on “entities and transactions” within the financial system.
Rule-making Authority	Writes rules, but rules can be vetoed by a two-thirds vote of a newly created council of bank regulators.	Full rule-making authority.	Full rule-making authority.
Covering Non-Bank Financial Firms	Rules apply to all banks, non-bank home lenders, and other “significant” non-banks.	Rules apply to all banks and non-banks, with some select exemptions (auto dealers, for example)	Rules apply to all banks and non-banks
Enforcement Authority	Only enforces rules for banks with more than $10 billion in assets. All others are overseen by their current regulator.	Only enforces rules for banks with more than $10 billion in assets. All others are overseen by their current regulator.	Full enforcement responsibilities.

Unfortunately, because the Bureau is going to be housed in the Fed, it is going to need every single one of those robust independence measures to ensure that it is not co-opted by a larger regulatory body that hasn’t historically been sympathetic to consumer concerns, and which is already dealing with a number of other major missions, including being designated the primary systemic risk regulator. In this environment, it is easy to see how a Fed-dominated Bureau would be ineffective.

Dodd’s Bureau as currently constructed is a good one, but if any of its key features are watered down, even a tiny bit, it will quickly become a bad proposal. So why go through all of these bells and whistles to establish independence for a Bureau within the Fed? Why not just establish a stand alone agency? And at the end of the day, how many Republican votes have been won by putting the Bureau within the Fed?

Today, Senate Banking Committee Chairman Chris Dodd (D-CT) plans to unveil his latest financial regulatory reform legislation, which will, by all accounts, vary significantly from the bill that he first proposed last November.

Since then, Dodd has gone through two rounds of negotiations. The first, with the banking committee’s ranking member, Sen. Richard Shelby (R-AL) ended at an “impasse,” and the second, with Sen. Bob Corker (R-TN) ended last week, after Dodd decided that the whole process was taking too long and it was time to move forward.

The highest profile item in the negotiations has been whether or not to create a Consumer Financial Protection Agency (CFPA) and where such an agency should be housed (if anywhere). Dodd’s initial proposal created a completely independent CFPA, but the negotiations with Corker produced a compromise in which a scaled-down CFPA would be placed within the Federal Reserve.

Details of the new bill are slowly leaking out, and according to various reports, Dodd is keeping many of the compromises reached with Corker, including housing the CFPA in the Fed and allowing a council of bank regulators to veto the CFPA’s rules (with a two-thirds vote). But including these provisions have earned Dodd a grand total of zero Republican votes:

Corker said Dodd’s new bill almost certainly would not get his and other Republicans’ support. Still, he said it will be “a huge improvement” over the initial proposal that Dodd released last November. “It will be a much better bill,” Corker said. “I think this last month has helped produce a far better product.”

Shelby added today that Republicans agree with 85 to 90 percent of the Dodd bill. Despite this, and characterizing it as a “huge improvement” and a “far better product,” the GOP still plans to offer Dodd absolutely no support.

With no GOP help forthcoming, it’s unclear why Dodd feels the need to retain the compromises that he made with Corker. If Republicans have already predetermined that they won’t join in, why not put forward a strong bill and force them to vote against it? There are enough Democrats on the banking committee to move a bill forward, and once it reaches the floor, some of the more moderate Republicans may be enticed into voting for it, while the rest will have to openly display their animosity toward financial reform and consumer protection.

Plus, Democrats now have the Fed’s Consumer Advisory Council (which was formed in 1976 to give the central bank input on consumer issues) on its side, which said in a letter to Dodd that it would be “imprudent” to house the CFPA at the Fed. “Consumers will be served only by having the C.F.P.A. as an independent agency where the primary responsibility is consumer protection,” the letter said.

Just like they did during the health care debate, Republicans are refusing to support a bill that includes their ideas, and calling for the process to slow down, claiming that if they receive more time to “review the language,” bipartisanship is still possible. Dodd should not only disregard this as a blatant attempt to obstruct the reform effort to death, but he should also put out the strongest bill that Democrats will support and dare the GOP to oppose it.