Is the mortgage crisis just a massive failure of consumer protection policy?

I mean, I am not a financial expert (not that experts appear to have fared so well!) - nor do I know much about mortgage (I don't even exactly have one...in France you mostly end up with some sort of state-sponsored mutual insurance on your housing loans, which mean your house is not mortgaged...). But then again, I am some kind of pseudo-expert on all things regulatory, at least outside of the financial sector. And one thing on which I have spent a lot of time (fighting corrupt bureaucrats loving to abuse their powers, particularly in the former Soviet Union) is consumer protection. So I know a tiny bit about it. And it strikes me that the reason this mortgage crisis is really huge in the US, and not in Europe, is consumer protection. European financiers are just as mad (madder?) and greedy (greedier?) as the American ones (and by the way, greed is arguably a virtue for a financier?) - so they invested in US mortgages, far more than in European ones (the UK might be a partial exception). Why? not just because the US had stronger growth - just simply because it had all these mortgages, I mean these crazy ones!

Why this is not discussed more broadly strikes me as a crazy form of US-centric provincialism: regulations on what loans financial institutions can be allowed to make to borrowers, and to what information they are required to provide to borrowers.
In other words:
- consumers/borrowers should be very clearly explained the risks and downsides of the products they take- some products might be too risky to be allowed altogether (not a favourite of mine but at least worth discussing)
- lenders could be required to strictly check the indebtedness of potential clients, and forbidden to lend beyond a certain limit (of course, if the client lied, s/he would be responsible
- but if the bank lent in spite of information meaning it should not have lent, it could find its loan agreement unenforceable).There has been much work on consumer/lender protection done in several EU states, including France (and including, another provision suggested in one of the posts, standardized loan agreements).

Experience suggests it works pretty well - again, European banks were just as greedy and dumb as US ones (see their exposure to sub-prime and CDOs etc.) and EU consumers are certainly not smarter than US ones - but there is no subprime mortgage crisis in, say, France or Germany. QED. Regulation makes sense when it is smart - consumer protection, through requirements to inform transparently and through interdiction of certain types of transactions, when too much risk is involved, is a good example. All regulatory reform experts now look far more to the EU as a place where smart regulation is being experimented, as to the US. Even the UK, when it developed a regulatory reform programme (Hampton Review), looked at the Netherlands - not at the US.