Even if the OCC, the FDIC, the Fed, and the OTS had miraculously managed to come to unanimous agreement on curtailing subprime lending, it still wouldn’t have helped much
Any subprime lenders which didn’t take deposits — and there were hundreds of them cropping up all over the country, originating loans and selling them on to investment banks to be packaged into bonds — would have remained outside the regulatory reach.\
http://www.portfolio.com/views/blogs/market-movers/2008/12/02/the-failed-subprime-clampdown?tid=true