One-Year Anniversary Dodd-Frank Progress Report
Davis Polk
July 22, 2011
Davis Polk & Wardwell LLP today a report analyzing the rulemaking and implementation progress of the Dodd-Frank Wall Street Reform and Consumer Protection Act following its one-year anniversary. The Progress Report contains a wide range of statistical data and graphical illustrations of the Dodd-Frank rulemaking process and takes into account the scores of rulemakings that had a July 21, 2011 deadline.
Among the key elements of the Progress Report:
- An analysis of rulemaking progress, which shows that regulators have completed 33, or 20%, of the 163 required rulemakings to date. Overall, regulators have completed 13% of all rulemaking requirements in Dodd-Frank.
- Rules fulfilling 13 rulemaking requirements were finalized in July and 104 rulemaking deadlines were missed – 76 on July 16, 2011 and 28 on July 21, 2011.
- A summary of study progress, which shows 7 missed studies to date.
- A ranking of the most popular topics of discussion in the more than 1,700 meetings that have taken place between regulators and market participants since Dodd-Frank's enactment.
- A graphical representation of the GAO's analysis of the $1.25 billion cost to regulators for Dodd-Frank implementation over the next two years.
- A breakdown, organized by affected groups within financial firms, of the 1,081 specific tasks identified by Davis Polk from CFTC and SEC releases that are applicable to swap dealers and major swap participants.
The analysis in the Progress Report is largely derived from the Davis Polk Regulatory Tracker, an online subscription service designed to help market participants, particularly their in-house legal and compliance departments, effectively navigate the Dodd-Frank Wall Street Reform and Consumer Protection Act and the regulatory phase of financial reform.