As Dodd-Frank's two year anniversary approaches "scores of rules that the law had mandated to be completed at this point are still uncompleted," writes American Banker's Donna Borak, citing analysis by the law firm Davis Polk & Wardwell.
"This was more than just filling in a few details. There were major components of the architecture that weren't there," said Margaret Tahyar of Davis Polk, about the required rules.
In the past "you had industry input into the legislation to make sure that there weren't any unintended consequences associated with the laws that were passed," explained Deborah Bailey of Deloitte & Touche. Because that didn't happen with Dodd-Frank, she says that input is being sought as part of the rulemaking process.
And the pace is declining, not accelerating. "Regulators are generally moving at a slower pace than they did initially, and under much tougher scrutiny. For every step forward, there seem to be two steps back, and even the rules they have accomplished have come after the Dodd-Frank-required deadlines," writes Borak.
Some observers approve of the take-your-time-do-it-right pace. "Progress is going forward. I'm satisfied,” says Barney Frank himself.
But there's a concern about lack of momentum: "If you wait too long, the uncertainty mounts and mounts and mounts," says H. Rodgin Cohen of Sullivan & Cromwell.
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