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E-MailThe following post comes to us from Margaret E. Tahyar and Gabriel D. Rosenberg of 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 November Davis Polk Dodd-Frank Progress Report, is the eighth 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:
- 37 New Deadlines – The Halfway Point. The 37 rulemaking deadlines due in October bring the number to date up to 200 – half of the 400 total required by the statute. To this point, only 23% of the rules due have been finalized.
- 10 Requirements Met, 30 Proposed, 37 Missed. A number of rulemakings were proposed or finalized this month, including:
- Proposed Volcker Rule Regulations – The FDIC, Federal Reserve, OCC and SEC released a coordinated proposed rule to implement the Volcker Rule. The CFTC has not yet released its proposed rule.
- FSOC Re-Proposal on SIFI Designation – The FSOC re-proposed a rule, along with guidance, on designation of nonbank financial companies as “systemically important.”
- SEC Proposed Rule on Registration – The SEC issued a proposed rule on registration of security-based swap dealers and major security-based swap participants.
- CFTC Proposal on Effective Date for Swap Regulation – The CFTC issued a proposed rule that would extend the latest date for its temporary Title VII relief until July 2012.
- CFTC Final Rule on Position Limits – The CFTC approved a final rule on position limits.
- CFTC Final Rule on DCOs – The CFTC approved a final rule on regulation of derivatives clearing organizations, combining several proposals into one 485-page final rule release.
