The Financial Services Roundtable, one of the big bank lobbying groups, said Friday it has filed 103 comment letters on the Dodd-Frank Act. That is up from an annual average of 13 letters previously, the tuckered-out lobbyists said.

Cynics might think of this tidal wave of helpful hints as yet another way the bankers frustrate efforts to keep them from ripping us off too brazenly. It is certainly good that the bankers are getting their say in the rulemaking process, because it’s not like we hear enough from the likes of JPMorgan Chase (JPM) chief Jamie Dimon as it is. New rules! Uncertainty! Weaker profits! What a tragedy!

But even after they blew up the economy in 2008, the bankers continue to insist that the problem is too many rules. Whatever happened to trust, they seem to ask.

“The scope of regulatory activity through Dodd-Frank has been just astounding,” said Steve Bartlett, CEO of the Roundtable. “The fast pace of rulemaking will certainly continue as 109 final rules are due to be adopted in the third-quarter of 2011 alone, and we are not even at the halfway mark for the rules called for under Dodd-Frank.”

Just as we surely haven’t scratched the surface of the lobbyists’ capacity for self-pity.