Unless I've missed it, this analysis skipped over the flexibility of being able to declare which specific assets are functioning as collateral through adding ne

Unless I've missed it, this analysis skipped over the flexibility of being able to declare which specific assets are functioning as collateral through adding new terms to loans. This would lower compliance costs further without being beholden to all the fixed rules they laid out (eg "FIFO"). For example if you're taking a huge loan above the thresholds, instead of just implicitly having that loan backed by everything you own, the terms can spell out which specific assets are functioning as collateral and that there is no recourse against you generally. Then only the gains on those recourse assets would be considered. (Though this whole topic might be a moot point now that interest rates exist again, and if the ZIRP monster is allowed to come back then we're screwed anyway)