Dodd-Frank Act Three Years Later Still A Work In Progress
By THE GLOBAL BANKING AND PAYMENT SYSTEMS PRACTICE GROUP
While the Dodd-Frank Act just passed its third anniversary, a number of major provisions are not yet implemented, and significant policy and legal issues remain unresolved. These include the Volcker Rule, Qualified Mortgage and Qualified Residential Mortgage Rules, Foreign Bank Supervision Rules, Orderly Liquidation Authority, Prudential Supervision Rules, Mortgage Disclosure Rules, GSE Reform, “Too Big To Fail” Policies, the Industrial Loan Company Moratorium, and Liquidity Standards. This client alert discusses the issues with these and other outstanding Dodd-Frank provisions, as well as the timing and potential challenges with implementation of final rules to complete the required reforms.