Both American and EU capitalism are heavily regulated. Both have concentrated on a lot of detailed regulation of financial services, and both have done it badly.
The EU dreams that there is a free wheeling US system and a cleverly regulated EU system. In times of trouble when US output wobbles, they come out and assert the answer is to move from American to EU capitalism. This is all absurd.
Over recent months despite all the rhetoric the US economy has fallen less than Germany or the UK. The EU, the UK and the US economies have all messed up their banking regulations, failing to demand enough capital in the good times, and then temporarily demanding too much cpaital in the bad times. Both the UK and the US have set interest rates that were too low in the good times and too high in the run up to the bad times.
How can anyone believe Mrs Merkel regulating the detail of hedge funds or Mr Brown running the investment banks would suddenly put the world to rights? The hedge funds and the investment banks that did overdo it could have been controlled properly if only the US, UK and EU regulators had behaved sensibly over the volume of credit and capital requirements in the heady days.
The fact that they did not is no argument for more regulation of a different kind. it is an argument to try and find a few regulators who know what they are doing, to set sensible limits to credit. If hedge funds and investment banks had been able to borrow less we would not be in the current mess.