WASHINGTON — A new analysis by the American Action Forum examines the cumulative costs and paperwork burdens of the Dodd-Frank Act roughly four years after the financial reform law's passage.

The report — titled "Dodd-Frank at 4: More Regulation, More Regulators, and a Sluggish Housing Market" — finds that the law has so far cost $21.8 billion.

"As time passes, the law becomes more expensive as regulatory agencies like" the Consumer Financial Protection Bureau and the Federal Housing Finance Agency "grow with the mission to implement burdensome rules," the study says. "Meanwhile, small financial services firms continue to struggle as the law restricts the availability of financial products. With about one-quarter of the law still left to implement, one can only expect the costs to continue to rise."

The study notes that calculation of the costs of certain regulations stemming from the bill could be higher, but the prudential banking agencies are allowed reporting discretion, resulting in data on some rules being incomplete.

For example, the group said data is lacking on the costs to businesses associated with implementing a requirement by the Federal Reserve Board that the biggest banks submit capital plans. Providing its own estimate in the report, the group said the cost of those Fed plans alone could be north of $13.8 million.

"There are at least 40 regulations that contain paperwork requirements, but omit cost data, accounting for 40.3 million hours, or more than two-thirds of the law's total paperwork burden," the report adds. "If regulators bothered to monetize these hours, even at a conservative $32.10 per hour, they would have added $1.2 billion in direct paperwork costs alone. Instead, the public is largely blind to the full costs and benefits of Dodd-Frank."

The report argues that the substantial costs of the law have restricted credit availability in the financial sector and growth in the banking industry.

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