Hersch said the government’s recent U-turn on buy-to-let regulation showed how inflexible the rules were.
He said: “It’s clear that there is very little room for the government to manoeuvre in but the EU Credit Directive is an ideal chance to harmonise regulation.
“However, it looks like this is unlikely to happen.”
Hersch made his comments in his opening address at the Association of Short Term Lenders annual conference in London.
The EU Mortgage Credit Directive is due to come into place in March 2016.