May 03, 2011
How's The Implementation of Dodd-Frank Coming Along?
Posted by David Zaring

In Davis Polk's view, not too well.  The firm has put together a nice set of slides on what looks like a regulatory exercise that is already beginning to appear a little winded, at a pretty early stage in the race.  The various financial regulators have now missed 30 statutory deadlines.  And they have a huge number of rules to get out - the rather tiny CFTC must promulgate 55 rules under the statute, only 8 of which don't come with a deadline, the SEC has to do 95, of which 75 are timed. Sarbanes Oxley put a lot of demands on the SEC's rulemakers too, but if memory serves, they made their very short deadlines then, in what must have been a lot of late nights. 

One interesting aspect of a statute that mandates a great deal of rulemaking in its aftermath is that it tends to create rulemaking traffic jams.  Check out the number of comments the CFTC has received in its open rulemakings, set forth below.  The agency is supposed respond to most of these in the process of getting out the final rule.  And they haven't exactly smoothed the intake over the months.  Davis Polk offers the commentary.  HT: Corp Counsel.


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