Regulatory Watch: Dodd-Frank by the (Page) Numbers

Regulatory Watch: Dodd-Frank by the (Page) Numbers

July 20, 2012

Happy 2nd Birthday DFA; Davis-Polk details the number of pages of rules Dodd-Frank has spawned. Banks lobby hardest.

Fri Reg and Accting - Law BooksIn July of 1776, the new American Congress conceived the concept of E Pluribus Unum – “Out of one, many.” It became the motto of the United States. In July 2010, a later Congressional generation conceived an opposite concept: Ex Uno Plures – “Out of one, many.” That is, out of one law, (well, actually, an 843-page law) many thousands of pages have been generated (E Plures Plures?).

Stacked 9 feet high.
According to law-firm and Dodd-Frank tracker Davis-Polk, the Dodd-Frank Act has generated 8,843 pages of rules and regulations. And the law is only 30 percent implemented. To illustrate who is generating what, Davis-Polk has created a handy chart of the fecund 2010 legislation. Here are some of the highlights:

  • The 8,843 rules have were created by more than 10 regulators, the brunt of which was done by the Securities and Exchange Commission (3200 pages) and Commodity Futures Trading Commission (3,187).
  • There are approximately 3363 pages dedicated to derivatives, 1561 dedicated to consumer protection and 820 dedicated to private funds. There are 379 pages for the systemic risk and 268 pages for the Volcker Rule. Another 2,200 pages of regulation is dedicated to other areas.
  • The fewest pages were generated by the Treasury’s Office of Financial Research which wrote just four pages of the new law.
  • In the derivatives area, “rulemaking to date gives rise to over 3700 tasks, many of which span multiple groups with firms.”

Busy bankers bobbing (and weaving).
Although Davis-Polk has a good handle on Dodd-Frank stats, there are many other firms counting the various numbers the Act is generating. One of them is Sunlight Foundation, a non-profit, nonpartisan organization that uses the Internet to help citizens keep track of government, has weighed in on the DFA’s second birthday to report that banks have been busy meeting with regulators over the legislation.

According to Sunlight: “In the two years since the mammoth Dodd–Frank Wall Street Reform and Consumer Protection Act became law, federal regulators have heard overwhelmingly from the biggest banks, according to a new Sunlight Foundation analysis of financial regulatory agency meeting logs.” Sunlight analyzed public meeting logs for the three major federal financial agencies: Treasury Department, the Federal Reserve and the Commodities Futures Trading Commission. Here’s what it found: the top 20 banks and banking associations met with regulators on average a combined 12.5 times per week for the last two years, for a total of 1,298 meetings. The same regulators only had 242 meetings (about 2.5 per week) with reform-oriented groups. … [Meeting leaders Goldman Sachs – 181 … JPMorgan Chase – 175 … Morgan Stanley – 150 … Bank of America – 122 … Citigroup – 102”

Happy Birthday Dodd-Frank.

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