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Dodd-Frank report: No progress on rules, some guidance

The recent Davis Polk Dodd-Frank Progress report revealed that no progress was made in implementing Dodd-Frank rules during the month of November, but regulators did provide markets with guidance and other “no-action relief.”

As of Dec. 3, only 33.4 percent of the total 398 rule-making requirements have been met with final rules, while rules have been proposed for another 33.4 percent. Rules have not yet been proposed for 33.2 percent of rule-making requirements.

Additionally, 237 Dodd-Frank rule-making deadlines have passed, accounting for 59.5 percent of all rule-making requirements and 84.6 percent of the 280 requirements with specific deadlines.

Of the 135 total rules for which they were responsible, banking regulators have missed the deadlines for 56 rules but have proposed rules for 46. Of the 45 rules with a future deadline, banking regulators have proposed seven rules.

The Commodity Futures Trading Commission has made the most progress on its rule-making requirements. The agency was assigned 60 total rules and has finalized approximately 67 percent of its rule-makings.

The Securities and Exchange Commission, however, lags behind other regulators in its implementation of assigned rules. Of the 95 rules assigned to the SEC, only 32 have been finalized. The SEC has missed 50 rule deadlines, eight of which remain unfinished.

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