Dodd-Frank Progress Report First Quarter 2015

Generated using the Davis Polk Regulatory Tracker™

In Brief: First Quarter 2015  4 Requirements Met, 2 Proposed. The SEC adopted Regulation SBSR, governing the reporting and public dissemination of security-based swap information, and a final rule on security-based swap data repository registration, duties and core principles. The Treasury Department released a proposed rule on recordkeeping requirements for qualified financial contracts related to the orderly liquidation authority. The SEC released a proposed rule on disclosure of hedging by employees and directors in annual meeting proxy statements.  1 Study. The CFPB released a study concerning the use of arbitration agreements in consumer finance markets.

State of Play to Date:  Of the 271 rulemaking requirements with deadlines that have passed, 180 (66.4%) have been met with finalized rules and rules have been proposed that would meet 58 (21.4%) more. Rules have not yet been proposed to meet 33 (12.2%) passed rulemaking requirements.  Of the 390 total rulemaking requirements, 235 (60.3%) have been met with finalized rules and rules have been proposed that would meet 71 (18.2%) more. Rules have not yet been proposed to meet 84 (21.5%) rulemaking requirements.

www.davispolkportal.com

2

Contents  Dodd-Frank Rulemaking Progress by Quarter

4

 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

3

Dodd-Frank Rulemaking Progress by Quarter

As of December 31, 2014 Missed Deadline: Proposed, 62

Future Deadline: Not Proposed, 52

Missed Deadline: Not Proposed, 39

As of March 31, 2015

Future Deadline: Proposed, 11

Missed Deadline: Proposed, 58

Future Deadline: Proposed, 13

Missed Deadline: Not Proposed, 33

Finalized, 231

Rulemaking counts are based on estimates and require judgment.

Future Deadline: Not Proposed, 51

Values Refer to Number of Rulemaking Requirements

Finalized, 235

4

Dodd-Frank Rulemaking Progress by Agency As of March 31, 2015 Bank Regulators (132)

CFTC (59)

Missed Deadline: Not Proposed, 7 Missed Deadline: Proposed, 19

Finalized, 77

Missed Deadline: Not Proposed, 1 Missed Deadline: Proposed, 7

Finalized, 50

Future Deadline: Not Proposed, 1

Future Deadline: Not Proposed, 23 Future Deadline: Proposed, 6 Missed Deadline: Proposed, 15 Missed Deadline: Not Proposed, 7

SEC (94)

Future Deadline: Proposed, 3

Finalized, 60

Rulemaking counts are based on estimates and require judgment.

Other (105)

Future Deadline: Not Proposed, 9

Finalized, 48

Future Deadline: Proposed, 4 Missed Deadline: Not Proposed, 18

Future Deadline: Not Proposed, 18

Values Refer to Number of Rulemaking Requirements

Missed Deadline: Proposed, 17 5

Dodd-Frank Rulemaking Progress on Passed Deadlines As of March 31, 2015 Total (271)

Finalized: Deadline Passed, 180, 66.4%

Missed Deadline: Proposed, 58, 21.4%

Missed Deadline: Not Proposed, 33, 12.2%

CFTC (53)

Bank Regulators (87)

Other (56)

SEC (75)

61, 70%

53, 71%

17, 30% 21, 38%

7, 13% 1, 2%

19, 22% 7, 8%

Rulemaking counts are based on estimates and require judgment.

45, 85%

15, 20% 7, 9%

Values Refer to Number of Rulemaking Requirements

18, 32% 6

Dodd-Frank Rulemaking Progress in Select Categories As of March 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

7

Dodd-Frank Study Progress by Due Date 4Q 2010

As of March 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)

8

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. © 2015 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 analysis of the matters presented and should not be relied upon as legal advice. If you would rather not receive these memoranda, please respond to this email and indicate that you would like to be removed from our distribution list. If you have received this email in error, please notify the sender immediately and destroy the original message, any attachments thereto and all copies. Refer to the firm's privacy policy located at davispolk.com for important information on this policy. Please add Davis Polk to your Safe Senders list or add [email protected] to your address book. For more information regarding the Progress Report, please contact [email protected]. For more information regarding the Davis Polk Regulatory Tracker™, please contact [email protected].

9

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]

Susan C. Ervin

202 962 7141

[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]

www.davispolkportal.com

10