The Dodd-Frank Wall Street Reform and Consumer Protection Act represents the most comprehensive financial regulatory reform measures taken since the great depression. So, one year after enactment, what do we know?
By the time you read this, we will have commemorated the first anniversary of the passage of the Dodd-Frank Act. Any significant milestone brings with it the opportunity for evaluation. The Act required that approximately 400 rules be written, of which 38 have been finalized. By and large the rules that have been finalized do not address or resolve the core systemic risk issues in the Act. Quite a number of rulemaking deadlines have been missed. The comment periods for many proposed rules were deemed too brief to allow for adequate consideration and discussion. A number of agencies have extended the comment periods, or re-proposed rules. Many agencies have acknowledged that a phased, or staged, implementation process is required given the possibility for disruption. This is especially true in the case of the regulations affecting OTC derivatives. In the meantime, as deadlines are extended, and as the debate regarding international competitiveness and the need for greater harmonization gains strength, legislators are proposing measures that would roll back certain reforms effected by the Act. With elections coming up, and with international reform measures dragging along, one cannot help but wonder how, when, or even if many of the Act's reforms will be put in place.
In the pages that follow, we summarize briefly the principal developments in several key areas. As lawyers, we would reflexively say that this is a summary, and only a very brief summary at that, and that all of this is qualified in its entirety by reference to our more complete (and far longer) descriptions, analyses and reports....As people who receive lots of summaries, we would say short is usually better. We hope you'll find these short summaries useful.
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