09/16/2010 03:54:00 PM EST
Wall Street Reform Bill Will Have Unique Impact on Small Companies

On July 21, 2010, President Obama signed the final
version of the Dodd-Frank Wall Street Reform and Consumer Protection Act into
law. This sweeping legislation will have a tremendous impact on institutions of
all sizes and industries, but not all companies will be impacted equally. It is
important for those who may be affected to understand what portions of the Act
will apply to them, and which will not; in particular, not all small banks,
holding companies, insurers, and issuers will be subject to all of the new
regulations. As these companies prepare for the regulatory changes that will
follow the implementation of the Act, close attention should be paid to
provisions which directly impact smaller institutions.
The Act affects small companies differently from their
larger counterparts in at least three distinct ways. First, it specifically
exempts some groups of companies from certain requirements of the Act. Second,
it directs federal regulatory agencies to consider how new rulemaking will
affect smaller institutions, and provides greater discretion in the choice to
exempt small institutions from their requirements. Finally, it mandates that
studies be conducted to identify the unique burdens imposed on these
institutions by new regulation.
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