Between the Financial Crisis Inquiry Commission’s launch, the FDIC risk-based fee and the Obama “bank tax,” now is really not a good time to be a bankster. Populism has finally reached Washington, and anything seen as harmful to the banks is suddenly good politics.

None of this means that anything will materially change; only that the opportunity for change now exists. For example, the Consumer Financial Protection Agency, feared dead in Senate negotiations, is now seemingly revived.

The fight in the Senate Banking Committee over the creation of a new agency dedicated to consumer financial protection has shifted from whether it should be created to what it will look like.

That’s a victory for consumer advocates, labor unions and the coalition of progressive groups fighting Wall Street over the shape of reform, but the banks still have several chances to ambush the proposed Consumer Financial Protection Agency as it moves through the Senate.

In a statement, Heather Booth, the executive director of the ad hoc group Americans for Financial Reform, said: “The Senate Banking Committee, with Chairman Dodd at the helm, will not be bowled over by the veiled threats of Wall Street lobbyists and will work for reform that will rein in the greedy, reckless behavior of the biggest banks. We look forward to working with them to achieve this goal.”

It’s possible that the banks are just shifting tactics, moving away from outright killing the CFPA and toward weakening it, in a form of regulatory capture. Nevertheless, it is striking how besieged the banks appear to be this week. Sheila Bair, one of the better regulators in this government, made a firm and succinct case for the FDIC asking for additional fees from member banks which overpay their CEOs to a degree that leads to excessive risk:

Ms. Bair: There are a number of MLRs (material loss reviews) for the smaller institutions that draw quite a clear contributing factor to bank failures on losses. We don’t have MLRs for the larger institutions because they got bailed out. That does not mean to say that we shouldn’t be looking at the huge compensation systems of the larger institutions as well, and how that fed into risk taking and the credit crisis which has obviously imposed massive losses for the deposit insurance fund. We must rely on academic research and other work done by our own staff to determine whether there is cause and effect here. We are asking the question right now but we are obliged to have risk adjusted premiums. And we are obliged to evaluate risk to the deposit insurance fund, and we are obliged to try to factor in those risk elements into our premium structure.

So I think there is nothing we are doing that conflicts with the Fed is doing. It complements that. There is nothing we are doing that conflicts with what the Congress is doing…

To suggest this agency shouldn’t do anything when there is such an overwhelming amount of evidence that this is clearly a contributor to the crisis and to the loses that we are suffering, I just cannot understand that.

Then there’s the Obama bank fee plan, set to be released as soon as tomorrow. This is designed, as per law, to recoup TARP losses. A senior Administration official said yesterday: “As the banking industry recovered the President and the economic team felt it was important to discuss ways to recoup every dime for the American people more quickly than the law required. The number would be no higher than 120 since that is the highest end of a conservative estimate of the cost of TARP, Treasury officials expect the number will be much lower and over the course of years the fee would pay back any cost to the taxpayer.”

And while this is a crowd-pleasing way to target voter anger about the bailouts, and is politically astute, The New York Times editorialized today that it should be combined with a windfall tax on bank bonuses.

This is an issue of fairness and sound public policy. The Treasury needs the money. A fee may also get banks and bankers to rethink the way they do business — something the much-promised, far-too-delayed and increasingly watered-down financial regulatory reform effort is unlikely to do. A permanent tax or fee imposed on the nation’s largest banks could reduce future risks by discouraging big banks from getting even bigger.

There just isn’t any shortage of juicy narratives that can be employed to support more regulation, more bank taxes, and more bonus clawbacks. Goldman Sachs just yesterday acknowledged front-running its clients.

Again, it’s not like banks are powerless. They have an entire Congress in their pocket, arguably. But it’s politically dicey to do anything but drive a stake through their heart right now. And that’s not likely to change in an election year.