Dodd-Frank Progress Report
Fourth Quarter 2015
Generated using the Davis Polk Regulatory Tracker™
In Brief: Fourth Quarter 2015
 18 Requirements Met. The CFTC adopted a final rule on margin requirements for uncleared
swaps, and the FCA, FDIC, Fed, FHFA and OCC adopted a joint final rule on margin, capital
and segregation requirements for covered swap entities. The Fed adopted a final rule on
emergency lending by Federal Reserve Banks. The CFPB adopted a final rule amending the
Home Mortgage Disclosure Act to include several new reporting requirements.
State of Play to Date:
 As of December 31, 2015, 271 rulemaking deadlines have passed. Of the 271 rulemaking
requirements with deadlines that have passed, 204 (75.3%) have been met with finalized rules
and rules have been proposed that would meet 34 (12.5%) more. Rules have not yet been
proposed to meet 33 (12.2%) passed rulemaking requirements.
 Of the 390 total rulemaking requirements, 267 (68.46%) have been met with finalized rules and
rules have been proposed that would meet 40 (10.26%) more. Rules have not yet been
proposed to meet 83 (21.28%) rulemaking requirements.
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Contents
 Dodd-Frank Rulemaking Progress
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 Dodd-Frank Rulemaking Progress by Agency
5
 Dodd-Frank Rulemaking Progress on Passed Deadlines
6
 Dodd-Frank Rulemaking Progress in Select Categories
7
 Dodd-Frank Study Progress by Due Date
8
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Dodd-Frank Rulemaking Progress by Quarter
As of September 30, 2015
Missed
Deadline:
Proposed, 45
Future
Deadline: Not
Proposed, 50
Missed
Deadline: Not
Proposed, 33
As of December 31, 2015
Missed
Deadline:
Proposed, 34
Future
Deadline:
Proposed, 13
Missed
Deadline: Not
Proposed, 33
Finalized, 249
Rulemaking counts are based on
estimates and require judgment.
Future
Deadline: Not
Proposed, 50
Future
Deadline:
Proposed, 6
Finalized, 267
Values Refer to Number of Rulemaking Requirements
4
Dodd-Frank Rulemaking Progress by Agency
As of December 31, 2015
Bank Regulators (132)
CFTC (59)
Future Deadline:
Proposed, 2
Missed
Deadline: Not
Proposed, 1
Future Deadline:
Not Proposed,
23
Missed
Deadline:
Proposed, 7
Finalized, 51
Missed
Deadline:
Proposed, 6
Finalized, 93
Future
Deadline: Not
Proposed, 1
Missed
Deadline: Not
Proposed, 7
SEC (94)
Future
Missed
Deadline: Not
Deadline:
Proposed, 8
Proposed, 14
Missed
Future
Deadline: Not
Deadline:
Proposed, 7
Proposed, 2
Finalized, 63
Rulemaking counts are based on
estimates and require judgment.
Other (105)
Finalized, 60
Future
Deadline:
Proposed, 2
Future
Deadline: Not
Proposed, 18
Missed
Deadline:
Proposed, 7
Missed
Deadline: Not
Proposed, 18
Values Refer to Number of Rulemaking Requirements
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Dodd-Frank Rulemaking Progress
on Passed Deadlines
As of December 31, 2015
Total (271)
Finalized:
Deadline
Passed, 204,
75.3%
Missed
Deadline:
Proposed, 34,
12.5%
Missed
Deadline: Not
Proposed, 33,
12.2%
CFTC (53)
Bank Regulators (87)
Other (56)
SEC (75)
73, 84%
31, 55%
54, 72%
7, 13%
46, 87%
6, 11%
1, 2%
7, 8%
7, 8%
14, 19%
7, 9%
Rulemaking counts are based on
estimates and require judgment.
18, 32%
Values Refer to Number of Rulemaking Requirements
6
Rulemaking counts are based on
Dodd-Frank Rulemaking Progress
in Select Categories
As of December 31, 2015
14
Asset-Backed Securities Offerings
44
Banking Regulations
6
Collins Amendment
63
Consumer Protection
22
Credit Rating Agencies
87
Derivatives
Finalized
14
Executive Comp. / Corp. Governance
Missed Deadline: Proposed
49
Mortgage Reforms
Missed Deadline: Not Proposed
Future Deadline: Proposed
16
Orderly Liquidation Authority
Future Deadline: Not Proposed
7
Investment Advisers / Private Funds
11
Investor Protection / Securities Laws
28
Systemic Risk
0
Rulemaking counts are based on
estimates and require judgment.
10
20
30
40
50
60
Number of Required Rulemakings
(Joint Rules are Counted for Each Applicable Agency)
70
80
90
100
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Dodd-Frank Study Progress by Due Date
4Q 2010
As of December 31, 2015
3
1Q 2011
21
2Q 2011
1
3Q 2011
17
4Q 2011
3
1Q 2012
16
2Q 2012
3Q 2012
12
4Q 2012
1Q 2013
4
2Q 2013
3Q 2013
4
4Q 2013
1Q 2014
2Q 2014
3Q 2014
4Q 2014
1Q 2015
2Q 2015
3Q 2015
4Q 2015
Not Specified
2
Annual
5
0
5
10
Finalized
Missed Deadline
15
20
25
Future Deadline
Number of Required Studies
(Joint Studies are Counted for Each Applicable Agency)
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About the Progress Report
 The Davis Polk Dodd-Frank Progress Report is a quarterly publication that uses empirical
data to help market participants and policymakers assess the progress of the rulemaking
and other work that has been done by regulators under the Dodd-Frank Act.
Access previous reports on our website.
 The Progress Report was developed using information from Davis Polk’s subscriptionbased Regulatory TrackerTM product. For more information on the Regulatory Tracker,
please contact [email protected] or view our brochure.
 Required, proposed, final and missed rulemakings and studies are counted based on
Davis Polk’s tally of statutory requirements in the Davis Polk Regulatory Tracker™. An
agency’s rule release may satisfy several statutorily required rulemakings.
 Where multiple agencies are required to issue a rule or study jointly, the requirement
appears in each of their totals, which we believe most accurately reflects the staff burden
on regulatory agencies.
 The term “Bank Regulators” includes the Board of Governors of the Federal Reserve, the
FDIC and the OCC.
© 2016 Davis Polk & Wardwell LLP. This publication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full
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For more information regarding the Progress Report, please contact [email protected].
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Questions?
If you have any questions regarding the matters covered in this Progress Report,
please contact any of the lawyers listed below or your regular Davis Polk contact.
Luigi L. De Ghenghi
212 450 4296
[email protected]
John L. Douglas
212 450 4145
[email protected]
Randall D. Guynn
212 450 4239
[email protected]
Annette L. Nazareth
202 962 7075
[email protected]
Christopher M. Paridon
202 962 7135
[email protected]
Lanny A. Schwartz
212 450 4174
[email protected]
Hilary S. Seo
212 450 4178
[email protected]
Margaret E. Tahyar
212 450 4379
[email protected]
Gabriel D. Rosenberg
212 450 4537
[email protected]
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