Three years and millions of words later, Dodd-Frank remains a work in slow progress.
Davis-Polk released its latest update of the status of implementation of the 2010 Dodd-Frank Act, revealing how things do not get done in Washington. But it hasn’t been for a lack of trying, as those agencies charged with writing the code have thrown millions of words at it. One startling fact: for every one word of law there have been 42 words published in the Federal Register. That’s more than 15 million words of rules, according to Davis-Polk’s latest implementation update.
According Davis-Polk’s annual report, in the three years since Dodd-Frank’s passage, the original 848 pages of statutory text has expanded to 13,789 pages. But there are many more words to go. “As of July 1, 2013, this staggering number represents only 39 percent of required rulemaking contained within Dodd-Frank.”
Other facts:
- As of July 15, 2013, a total of 279 Dodd-Frank rulemaking requirement deadlines have passed. This is 70.1% of the 398 total rulemaking requirements, and 99.6% of the 280 rulemaking requirements with specified deadlines.
- Of these 279 passed deadlines, 172 (61.6%) have been missed and 107 (38.4%) have been met with finalized rules. Regulators have not yet released proposals for 64 of the 172 missed rules.
- Of the 398 total rulemaking requirements, 158 (39.7%) have been met with finalized rules and rules have been proposed that would meet 113 (28.4%) more. Rules have not yet been proposed to meet 127 (31.9%) rulemaking requirements.
On the bright side, Davis-Polk said the pace of Dodd-Frank implementation “has been remarkably consistent over the past three years.” Perhaps this is the “foolish consistency” that Ralph Waldo Emerson alluded to when he said that such consistency is the “hobgoblin of little minds.”