dodd frank progress update

7/27/2019 Dodd Frank Progress Update

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Dodd-FrankProgress Report

Generated using theDavis Polk Regulatory Tracker

July 15, 2013
http://www.davispolk.com/dodd-frank/regulatory-tracker/http://www.davispolk.com/dodd-frank/regulatory-tracker/http://www.davispolk.com/dodd-frank/regulatory-tracker/http://www.davispolk.com/dodd-frank/regulatory-tracker/http://www.davispolk.com/


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Dodd-Frank: Three Years Later

www.davispolkportal.com

State of Play to Date:

As of July 15, 2013, a total of 279Dodd-Frank rulemaking requirement

deadlines have passed. This is

70.1% of the 398 total rulemaking

requirements, and 99.6% of the 280

rulemaking requirements with

specified deadlines.

Of these 279 passed deadlines, 172(61.6%) have been missed and 107

(38.4%) have been met with finalized

rules. Regulators have not yet

released proposals for 64 of the 172

missed rules.

Of the 398 total rulemakingrequirements, 158 (39.7%) have

been met with finalized rules and

rules have been proposed that

would meet 113 (28.4%) more.

Rules have not yet been proposed to

meet 127 (31.9%) rulemaking

requirements.2


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Contents

Infographic: Dodd-Frank at the Three-Year Mark 4

Dodd-Frank Rulemaking Progress by Agency 5

Title VII Progress on Required Rulemakings 6

Dodd-Frank Rulemaking Progress on Passed Deadlines 7

Dodd-Frank Rulemaking Progress in Select Categories 8

Dodd-Frank Rulemaking Progress by Due Date 9 Dodd-Frank Statutory Deadlines for Required Rulemakings 10

Dodd-Frank Study Progress by Due Date 11

Dodd-Frank Statutory Deadlines for Required Studies 12

3


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Infographic: Dodd-Frank at the Three-Year Mark

www.davispolkportal.com

The three years since Dodd-Franks

passage have seen 848 pages of statutory

text expand to 13,789 pages more than15 million words of regulation. As of July 1,2013, this staggering number represents

only 39% of required rulemaking contained

within Dodd-Frank. In this infographic, we

visually describe the pace of Dodd-Frank

implementation, which has been

remarkably consistent over the past three

years. Follow this link to view more:http://www.davispolkportal.com

4
http://www.davispolkportal.com/infographic/july2013infographic.html


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Values Refer to Number of Rulemaking RequirementsRulemaking counts are based onestimates and require judgment.

Dodd-Frank Rulemaking Progress by Agency

Future

Deadline: Not

Proposed, 12

Finalized, 35

Missed

Deadline: Not

Proposed, 8

Missed

Deadline:

Proposed, 40

Future Deadline:Not Proposed,

29

Future Deadline:

Proposed, 1

Finalized, 43Missed

Deadline: NotProposed, 17

MissedDeadline:

Proposed, 45

Future

Deadline: Not

Proposed, 1

Future

Deadline:

Proposed, 1

Finalized, 41

Missed

Deadline: Not

Proposed, 6

Missed

Deadline:

Proposed, 11

SEC (95)

CFTC (60)

Other (108)

As of July 15, 2013

Future

Deadline: Not

Proposed, 21

Future

Deadline:

Proposed, 3

Finalized, 39

Missed

Deadline: Not

Proposed, 33

Missed

Deadline:

Proposed, 12

Bank Regulators (135)

5
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Missed Deadline: Not

Proposed, 11

Missed Deadline: Proposed,

31

Finalized, 48

Missed

Deadline: Not

Proposed, 4

Missed

Deadline:

Proposed, 4

Finalized, 35

CFTC Progress on Required Title VII Rulemakings

Missed

Deadline: Not

Proposed, 2

Missed

Deadline:

Proposed, 17

Finalized, 10

SEC Progress on Required Title VII Rulemakings

As of July 15, 2013

Title VII Progress on Required Rulemakings

6


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Dodd-Frank Rulemaking Progress

on Passed DeadlinesAs of July 15, 2013

8, 10%

40, 53%

28, 37%

17, 19%

45, 50%

28, 31%

Missed Deadline:

Not Proposed,

64, 22.9%

Missed Deadline:Proposed, 108,

38.7%

Finalized:

Deadline

Passed, 107,

38.4%

6, 11%

11, 20%

37, 69%

Bank Regulators (90) Other (59)SEC (76)

Total (279)

Values Refer to Number of Rulemaking RequirementsRulemaking counts are based onestimates and require judgment.

CFTC (54)

33, 56%

12, 20%

14, 24%

7


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14

44

6

63

22

90

14

49

21

7

11

28

0 10 20 30 40 50 60 70 80 90 100

Asset-Backed Securities Offerings

Banking Regulations

Collins Amendment

Consumer Protection

Credit Rating Agencies

Derivatives

Executive Comp. / Corp. Governance

Mortgage Reforms

Orderly Liquidation Authority

Investment Advisers / Private Funds

Investor Protection / Securities Laws

Systemic Risk

Finalized

Missed Deadline: Proposed

Missed Deadline: Not Proposed

Future Deadline: Proposed

Future Deadline: Not Proposed

As of July 15, 2013

Number of Required Rulemakings(Joint Rules are Counted for Each Applicable Agency)

Dodd-Frank Rulemaking Progress

in Select Categories

Rulemaking counts are based onestimates and require judgment.

8


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1

4

9

26

119

37

25

16

42

1

116

2

0 20 40 60 80 100 120 140

3Q 2010

4Q 2010

1Q 2011

2Q 2011

3Q 2011

4Q 2011

1Q 2012

2Q 2012

3Q 2012

4Q 2012

1Q 2013

2Q 2013

3Q 2013

4Q 2013

Not Specified

Annual

Finalized

Missed Deadline: Proposed

Missed Deadline: Not Proposed

Future Deadline: Proposed

Future Deadline: Not Proposed

As of July 15, 2013

Dodd-Frank Rulemaking Progress by Due Date


Rulemaking counts are based onestimates and require judgment.9


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1

4

9

26

119

37

25

16

42

1

116

2

0 20 40 60 80 100 120 140

3Q 2010

4Q 2010

1Q 2011

2Q 2011

3Q 2011

4Q 2011

1Q 2012

2Q 2012

3Q 2012

4Q 2012

1Q 2013

2Q 2013

3Q 2013

4Q 2013

Not Specified

Annual

Bank Regulators CFPB CFTC SEC Other


Rulemaking counts are based onestimates and require judgment.

Dodd-Frank Statutory Deadlines for

Required Rulemakings

10


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3

21

1

17

3

16

12

4

4

2

5

0 5 10 15 20 25

4Q 2010

1Q 2011

2Q 2011

3Q 2011

4Q 2011

1Q 2012

2Q 2012

3Q 2012

4Q 2012

1Q 2013

2Q 2013

3Q 2013

4Q 2013

Not Specified

Annual

Finalized Missed Deadline Future Deadline

As of July 15, 2013

Dodd-Frank Study Progress by Due Date

Number of Required Studies(Joint Studies are Counted for Each Applicable Agency)

11


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3

21

1

17

3

16

12

4

4

2

5

0 5 10 15 20 25

4Q 2010

1Q 2011

2Q 2011

3Q 2011

4Q 2011

1Q 2012

2Q 2012

3Q 2012

4Q 2012

1Q 2013

2Q 2013

3Q 2013

4Q 2013

Not Specified

Annual

Bank Regulators CFTC GAO SEC Other

Dodd-Frank Statutory Deadlines

for Required Studies

Number of Required Studies(Joint Studies are Counted for Each Applicable Agency)

12


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The Davis Polk Dodd-Frank Progress Report is a monthly publication that uses empirical

data to help market participants and policymakers assess the progress of the rulemakingand other work that has been done by regulators under the Dodd-Frank Act.

Access previous reports on our website.

The Progress Report was developed using information from Davis Polks subscription-

based Regulatory TrackerTM product. For more information on the Regulatory Tracker,

please [email protected] view our brochure. Required, proposed, final and missed rulemakings and studies are counted based on

Davis Polks tally of statutory requirements in the Davis Polk Regulatory Tracker. An

agencys rule release may satisfy several statutorily required rulemakings.

Where multiple agencies are required to issue a rule or study jointly, the requirement

appears in each of their totals, which we believe most accurately reflects the staff burden

on regulatory agencies. The term Bank Regulatorsincludes the Board of Governors of the Federal Reserve, the

FDIC and the OCC.

About the Progress Report

2013 Davis Polk & Wardwell LLP. This publication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full

analysis of the matters presented and should not be relied upon as legal advice. If you would rather not receive these memoranda, please respond to this email and indicate

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For more information regarding the Progress Report, please contact [email protected].

For more information regarding the Davis Polk Regulatory Tracker, please contact [email protected]
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Daniel N. Budofsky 212 450 4907 [email protected]

Luigi L. De Ghenghi 212 450 4296 [email protected]

John L. Douglas 212 450 4145 [email protected]

Susan C. Ervin 202 962 7141 [email protected]

Randall D. Guynn 212 450 4239 [email protected]

Annette L. Nazareth 202 962 7075 [email protected]

Lanny A. Schwartz 212 450 4174 [email protected]

Margaret E. Tahyar 212 450 4379 [email protected]

Gabriel D. Rosenberg 212 450 4537 [email protected]

If you have any questions regarding the matters covered in this Progress Report,

please contact any of the lawyers listed below or your regular Davis Polk contact.

Questions?

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