Well, as is typical of crisis legislation, DF had many provisions crafted in haste and even as the law was being passed, its imperfections were pretty clear. I'd say in the years since the law’s passage, the fundamental flaws have become more evident. DF not only failed effectively to respond to the crisis, but it also created/creates (?) unintended consequences that could lay the groundwork for a future financial crisis.
My main criticism is that DF didn't solve the "too-big-to-fail" problem; in fact it did institutionalize it. Those firms that are designated as 2B2F essentially receive special reg treatment, and I bet there's an unspoken commitment to step in to save the 2B2F firms and their creditors at the first sign of trouble. This basically translates into a perverse incentive by 2B2F to take on more risk, and results in the entrenchment of big players to the expense of smaller ones. The sheer complexity and of DF gives an edge to bigger players who are able to bear the cost of legal/compliance teams (armies!) much better than smaller players. Likewise in the asset management community, you've seen start up costs balloon, which drives away competition all the while the BlackRocks, Pimcos, DoubleLines of the world have seen their AUM grow tremendously. So, you have higher concentration of risk and the effects on small banks, asset managers, hedge funds are certainly profound. As a financial consumer you're left with to decreased choice and increased costs. (Ben Bernanke was recently turned down for a mortgage refi - lol)
Then you have large clearinghouses with taxpayers as backstops and the role of the Gov't in the mortgage market has increased rather than decreased.
The most striking omission is the failure to address/reform the Freddie Mac and Fannie Mae, which were at the heart of the housing crisis. To date there hasn't been any meaningful reform in the housing sector, which caused the crisis in the first place. Talk about special interest groups keeping the status quo!
Finally, implementation itself has been a disaster. The process has not kept up with statutory requirements and many deadlines have been missed. It took forever to agree on a definition of “derivatives” which is a central concept of DF. Basically Congress left key decisions to regulators and gave them discretion to define the limits of their own authority. It essentially just gave them more levers to pull and buttons to push hoping to micromanage the market. The whole situation of expanding the role of regulators in the aftermath of a financial crisis in which regulators were asleep at the wheel is ironic at best. No regulatory body was held accountable for reg failures, instead they were given new powers.
One of the great mistakes is to judge policies and programs by their intentions rather than their results. Time will tell how DF will pan out in the end...