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February 5, 2013

Over Half of Dodd-Frank Deadlines Have Been Missed

By Lene Powell, J.D.

As reported in Davis Polk's Dodd-Frank Progress Report for the month of January, regulators continue to miss rulemaking deadlines. In all, 46 deadlines, 42 rulemaking requirements, and 4 studies were due in January. Of those requirements, only 12 were met with finalized rules. No new rules were proposed.

Some agencies did issue final rules in January, the report noted. The CFPB released final rules on qualified mortgage standards, mortgage servicing and loan originator compensation. The CFPB, FDIC, Federal Reserve, FHFA, NCUA and OCC released a joint final rule that establishes new appraisal requirements for higher-priced mortgage loans. In addition, the GAO issued a study analyzing financial services regulations.

Total progress to date. A total of 279 Dodd-Frank rulemaking requirement deadlines have passed as of February 1, 2013, according to the report, representing almost all rulemaking requirements with specified deadlines and 70% of rulemaking requirements in total. Of the passed deadlines, 176 (63%) have been missed, while 103 (40%) have been met with finalized rules. (Numbers have been rounded.)

Of the 176 missed rules, regulators have not yet released proposals for 65. Regarding the 398 total rulemaking requirements, roughly a third have been met with finalized rules (37%) and another third with proposed rules (30%). For the remaining third, rules have not yet been proposed (32%).

Overall, the proportion of finalized rules varies significantly by agency. The CFTC has finalized two-thirds of its required rules (40 of 60), whereas the SEC has finalized about one-third (33 of 95). The banking regulators (Federal Reserve, the FDIC and the OCC) have finalized less than a quarter of their required rules (37 of 135).

Title VII. Progress has been a little better for Title VII rules. Across all agencies, a little over half of required Title VII rules have been finalized, with 47 rules finalized of the 90 required.

The report notes that rulemaking counts are based on estimates and require judgment.

RegulatoryActivity: DoddFrankAct ExchangesMarketRegulation

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