One-Year Anniversary Dodd-Frank Rulemaking Progress Report

Margaret E. Tahyar is a partner in the Financial Institutions Group at Davis Polk & Wardwell LLP. This post discusses a Davis Polk report which is available here. A post about the previous progress report is available here. This post is part of a series following the first anniversary of the Dodd-Frank Act which was July 21, 2011, other Dodd-Frank posts are available here.

This posting, the Davis Polk Dodd-Frank Rulemaking Progress Report, is the fifth in a series of Davis Polk presentations that illustrate graphically the progress of the rulemaking work that has been done and is yet to occur under the Dodd-Frank Act. The Progress Report has been prepared using data from the Davis Polk Regulatory Tracker™, an online subscription service offered by Davis Polk to help market participants understand the Dodd-Frank Act and follow regulatory developments on a real-time basis.

Among the key elements of this Progress Report:

  • An analysis of rulemaking progress, which shows that regulators have completed 33, or 20%, of the 163 rulemakings due to date. Overall, regulators have completed 13% of all rulemaking requirements in Dodd-Frank.  Rules fulfilling 13 rulemaking requirements were finalized in July and 104 rulemaking deadlines were missed – 76 on July 16, 2011 and 28 on July 21, 2011.
  • A summary of study progress, which shows 7 missed studies to date.
  • A ranking of the most popular topics of discussion in the more than 1,700 meetings that have taken place between regulators and market participants since Dodd-Frank’s enactment.
  • A graphical representation of the GAO’s analysis of the $1.25 billion cost to regulators for Dodd-Frank implementation over the next two years.
  • A breakdown, organized by affected groups within financial firms, of the 1,081 specific tasks identified by Davis Polk from CFTC and SEC releases that are applicable to swap dealers and major swap participants.
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