More than half of the Dodd-Frank financial reform law has been fully implemented three and a half years after its enactment.
As of Jan. 2, 50.5 percent of all Dodd-Frank rules have been finalized, according to outside analysis by the law firm Davis Polk. Regulators have proposed rules for another 21.9 percent of the Wall Street overhaul’s rule-making requirements, leaving 27.6 percent of the law still untouched by regulators.
Furthermore, regulators have now passed all 280 deadlines stipulated by the law. But that does not mean they have met all those deadlines. According to Davis Polk, regulators have met slightly more than half of the statutory deadlines of the law, 52.9 percent. Of the 47.1 percent of deadlines that have come and gone, regulators have not yet proposed any rule for 42.4 percent of them.
December was a significant month for financial regulators on the Dodd-Frank front, with five watchdog agencies coming together to finalize rules implementing one of the law’s most significant, and contentious, provisions.
Regulators finalized rules implementing the “Volcker Rule,” a ban on risky proprietary trading by banks, after years’ of work and significant pushback from the financial industry. However, those rules are already being revisited as regulators have agreed to reconsider a small, specific portion of the rules after the financial industry said it could improperly hurt small community banks not targeted by the provision.
Finalizing the Volcker Rule constituted a significant piece of the 36 rule-making requirements regulators wrapped up in December. In addition, the Federal Insurance Office, another Dodd-Frank creation, released a study that month analyzing the insurance industry.
While regulators now officially have less Dodd-Frank rule-writing ahead of them than they had already completed, the pending workload varies widely from watchdog to watchdog.
For example, the Securities and Exchange Commission faced 95 rule-making requirements from Dodd-Frank. Of that amount, 42 have been finalized, or 44 percent of its workload. Thirty-five rules have been proposed, while another 18 still are in the works.
Meanwhile, the Commodity Futures Trading Commission has finalized 83 percent of the 60 rules it was required to write, having completed 50 of the items on its agenda. Another seven rules have been proposed, leaving three projects still without at least proposed rules.