September 2011 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. Other posts about the Dodd-Frank Act are available here.

This posting, the September Davis Polk Dodd-Frank Progress Report, is the sixth 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.

In this report:

  • No New Deadlines. No new rulemaking requirements were due in August.
  • 9 Requirements Met, 3 Proposed. Four deadlines that had been previously missed were met, and five with future deadlines were finalized. Two of the proposed rules, one from the SEC and one from the Federal Reserve, appear as missed requirements as their deadlines have passed.
  • Bank Regulators. Although August was a quiet month for the Bank Regulators, they are expected to take action on several key items in the coming months, including issuing rules regarding resolution plans and implementation of the Volcker Rule.
  • CFPB Begins Rulemaking. The CFPB finalized its first 5 rules in late July. None had a statutory deadline.
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