October 2011 Dodd-Frank Rulemaking Progress Report

This posting, the October Davis Polk Dodd-Frank Progress Report, is the seventh 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 September.
• 3 Requirements Met, 1 Proposed. Three rulemaking requirements were finalized this month, including the FDIC’s Joint Final Rule on Resolution Plans (also known as “living wills”). The Federal Reserve is expected to issue their version of the rule soon. One rule was proposed for which the deadline had already passed.
• Volcker Rule Expected. A coordinated proposed rule on implementation of the Volcker Rule is expected in the coming weeks.
• 2 Studies Issued. The GAO and the SEC each published one study in September.
• New Progress Report Feature. The Progress Report now divides missed deadlines into those for which a proposed rule has been published and those for which no proposed rule has been published. As deadlines are missed, this will help readers gauge progress.