This posting, the October 2012 Davis Polk Dodd-Frank Progress Report, is one in a series of Davis Polk presentations that illustrate graphically the progress of the rulemaking work that has been done and is yet to occur under the Dodd-Frank Act. The Progress Report has been prepared using data from the Davis Polk Regulatory Tracker™, an online subscription service offered by Davis Polk to help market participants understand the Dodd-Frank Act and follow regulatory developments on a real-time basis.
In this report:
- As of October 1, 2012, a total of 237 Dodd-Frank rulemaking requirement deadlines have passed. Of these 237 passed deadlines, 149 (62.9%) have been missed and 88 (37.1%) have been met with finalized rules.
- In addition, 127 (31.9%) of the 398 total required rulemakings have been finalized, while 136 (34.2%) rulemaking requirements have not yet been proposed.
- This month, the CFTC Final Rule on Position Limits was vacated in a decision of the U.S. District Court for the District of Columbia.