In general I think the US is comfortable to limp along putting band-aids on broken systems, because the failings are seen as being intrinsic to the "natural state" of things (see also: common law and court precedent reigning), and the losses are ultimately sustainable. The possibility of a fraudulent transaction can never be eliminated, so therefore it's whatever party facilitates/blesses the transaction that fully bears the responsibility. Meanwhile the EU doesn't seem afraid to create new foundational semantics - eg get rid of the concept of "pulling" money, and then dictate that banks cannot charge customers for the equivalent of initiating an ACH push [0].
[0] Bank of America actually charges for this. They also charge for walk-in cashing of checks drawn on themselves - meaning they are inducing their own customers to write fraudulent checks!