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Dodd-Frank Progress Report
Generated using the Davis Polk Regulatory Tracker™
Fourth Quarter 2015
In Brief: Fourth Quarter 2015
18 Requirements Met. The CFTC adopted a final rule on margin requirements for uncleared swaps, and the FCA, FDIC, Fed, FHFA and OCC adopted a joint final rule on margin, capital and segregation requirements for covered swap entities. The Fed adopted a final rule on emergency lending by Federal Reserve Banks. The CFPB adopted a final rule amending the Home Mortgage Disclosure Act to include several new reporting requirements.
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State of Play to Date:
As of December 31, 2015, 271 rulemaking deadlines have passed. Of the 271 rulemaking requirements with deadlines that have passed, 204 (75.3%) have been met with finalized rules and rules have been proposed that would meet 34 (12.5%) more. Rules have not yet been proposed to meet 33 (12.2%) passed rulemaking requirements.
Of the 390 total rulemaking requirements, 267 (68.46%) have been met with finalized rules and rules have been proposed that would meet 40 (10.26%) more. Rules have not yet been proposed to meet 83 (21.28%) rulemaking requirements.
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Contents
Dodd-Frank Rulemaking Progress 4
Dodd-Frank Rulemaking Progress by Agency 5
Dodd-Frank Rulemaking Progress on Passed Deadlines 6
Dodd-Frank Rulemaking Progress in Select Categories 7
Dodd-Frank Study Progress by Due Date 8
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Values Refer to Number of Rulemaking Requirements Rulemaking counts are based on estimates and require judgment.
Dodd-Frank Rulemaking Progress by Quarter
Future Deadline: Not Proposed, 50
Future Deadline:
Proposed, 6
Finalized, 267
Missed Deadline: Not Proposed, 33
Missed Deadline:
Proposed, 34
Future Deadline: Not Proposed, 50
Future Deadline:
Proposed, 13
Finalized, 249
Missed Deadline: Not Proposed, 33
Missed Deadline:
Proposed, 45
As of December 31, 2015 As of September 30, 2015
4
Values Refer to Number of Rulemaking Requirements Rulemaking counts are based on estimates and require judgment.
Dodd-Frank Rulemaking Progress by Agency
Future Deadline: Not Proposed,
23
Future Deadline: Proposed, 2
Finalized, 93
Missed Deadline: Not Proposed, 7
Missed Deadline:
Proposed, 7
Future Deadline: Not Proposed, 1
Finalized, 51
Missed Deadline: Not Proposed, 1
Missed
Deadline: Proposed, 6
SEC (94)
CFTC (59)
Other (105)
Bank Regulators (132)
As of December 31, 2015
Future Deadline: Not Proposed, 18
Future Deadline:
Proposed, 2
Finalized, 60
Missed Deadline: Not Proposed, 18
Missed Deadline:
Proposed, 7
Future Deadline: Not Proposed, 8
Future Deadline:
Proposed, 2
Finalized, 63
Missed Deadline: Not Proposed, 7
Missed Deadline:
Proposed, 14
5
Missed Deadline: Not Proposed, 33,
12.2%
Missed Deadline:
Proposed, 34, 12.5%
Finalized: Deadline
Passed, 204, 75.3%
1, 2%
6, 11% 46, 87%
7, 9%
14, 19%
54, 72%
Rulemaking counts are based on
Bank Regulators (87) Other (56) SEC (75)
Total (271)
Values Refer to Number of Rulemaking Requirements Rulemaking counts are based on estimates and require judgment.
CFTC (53)
Dodd-Frank Rulemaking Progress on Passed Deadlines
As of December 31, 2015
7, 8% 7, 8%
73, 84%
18, 32%
7, 13%
31, 55%
6
14
44
6
63
22
87
14
49
16
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 December 31, 2015
Number of Required Rulemakings (Joint Rules are Counted for Each Applicable Agency)
Dodd-Frank Rulemaking Progress in Select Categories
Rulemaking counts are based on estimates and require judgment.
7
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
1Q 2014
2Q 2014
3Q 2014
4Q 2014
1Q 2015
2Q 2015
3Q 2015
4Q 2015
Not Specified
Annual
Finalized Missed Deadline Future Deadline
As of December 31, 2015
Dodd-Frank Study Progress by Due Date
Number of Required Studies (Joint Studies are Counted for Each Applicable Agency)
8
The Davis Polk Dodd-Frank Progress Report is a quarterly publication that uses empirical data to help market participants and policymakers assess the progress of the rulemaking and 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 Polk’s subscription-based Regulatory TrackerTM product. For more information on the Regulatory Tracker, please contact [email protected] or view our brochure.
Required, proposed, final and missed rulemakings and studies are counted based on Davis Polk’s tally of statutory requirements in the Davis Polk Regulatory Tracker™. An agency’s 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 Regulators” includes the Board of Governors of the Federal Reserve, the FDIC and the OCC.
About the Progress Report
© 2016 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 that you would like to be removed from our distribution list. If you have received this email in error, please notify the sender immediately and destroy the original message, any attachments thereto and all copies. Refer to the firm's privacy policy located at davispolk.com for important information on this policy. Please add Davis Polk to your Safe Senders list or add [email protected] to your address book. For more information regarding the Progress Report, please contact [email protected]. For more information regarding the Davis Polk Regulatory Tracker™, please contact [email protected]. 9
Luigi L. De Ghenghi 212 450 4296 [email protected]
John L. Douglas 212 450 4145 [email protected]
Randall D. Guynn 212 450 4239 [email protected]
Annette L. Nazareth 202 962 7075 [email protected]
Christopher M. Paridon 202 962 7135 [email protected]
Lanny A. Schwartz 212 450 4174 [email protected]
Hilary S. Seo 212 450 4178 [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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