July 2012 Dodd-Frank Progress Report

The 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 July 2012 Davis Polk Dodd-Frank Progress Report, is one 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:

  • As of July 2, 2012, a total of 221 Dodd-Frank rulemaking requirement deadlines have passed. Of these 221 passed deadlines, 140 (63%) have been missed and 81 (37%) have been met with finalized rules.
  • In addition, 119 (29.9%) of the 398 total required rulemakings have been finalized, while 142 (35.7%) rulemaking requirements have not yet been proposed.
  • Major rulemaking activity this month included the FDIC, Federal Reserve and OCC joint final rule on market risk capital standards and the FDIC proposed rule on the definition of “predominantly engaged in financial activities” for purposes of Orderly Liquidation Authority. Additionally, though not explicitly required by Dodd-Frank, the CFTC released proposed interpretive guidance and a proposed order related to the cross-border application of Title VII.
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