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. Another memorandum from Morrison Foerster LLP about the two-year anniversary of the Dodd-Frank Act is available here. Other posts about the Dodd-Frank Act are available here.
This posting, the Davis Polk Two-Year Anniversary Dodd-Frank Progress Report, is one in a series of Davis Polk presentations that graphically track the rulemaking required by the Dodd-Frank Act. The Progress Reports are 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.
The special Progress Report marks the two-year anniversary of Dodd-Frank. The state-of-play at the end of this second year of regulatory implementation can be described as follows:
- As of July 18, 2012, a total of 221 Dodd-Frank rulemaking requirement deadlines have passed. This is 55.5% of the 398 total rulemaking requirements, and 78.9% of the 280 rulemaking requirements with specified deadlines.
- Of these 221 passed deadlines, 136 (61.5%) have been missed and 85 (38.5%) have been met with finalized rules. Regulators have not yet released proposals for 19 of the 136 missed rules.
- Of the 398 total rulemaking requirements, 123 (30.9%) have been met with finalized rules and rules have been proposed that would meet 134 (33.7%) more. Rules have not yet been proposed to meet 141 (35.4%) rulemaking requirements.
To highlight the occasion, we have developed several additional features that visually describe aspects of Dodd-Frank in new ways: