Thursday, June 23, 2011

Tracking the Implementation of the Dodd-Frank Act

Robert J. Novak

The Dodd–Frank Wall Street Reform and Consumer Protection Act was enacted into law on July 21, 2010. Designed to become effective in stages, many of the Act’s provisions require regulatory implementation through various rulemakings and studies. The implementation process is complex and evolving, and tracking its status can be challenging for even those governmental and industry insiders who are actively involved in it. So how can bank directors and officers—those who are most impacted by the Act and who will be held responsible for understanding and adhering to it—follow along?

While there are many online resources available to bank directors and officers, one that we’ve found to be a good resource for following the latest developments concerning the implementation of the Act is the ABA’s “Dodd-Frank Tracker” website, available here. Three features of this website, in particular, are worth highlighting. First, the Dodd-Frank calendar. This calendar tracks (i) all relevant legislative and regulatory hearings and meetings, (ii) the deadlines to comment on proposed rules, and (iii) the various effective dates of the Act and the regulations implementing it. It also provides hyperlinks to the proposals at issue and other relevant information, for those interested in learning more. Second, the topical webpages. The ABA has organized much of the site’s content around discrete Dodd-Frank topics. This allows visitors to click on a specific topical link, such as Interchange Fees, and view a webpage containing posts related exclusively to that topic. Like the Dodd-Frank calendar, the topical webpages are all embedded with hyperlinks to further reading, which include, among other things, regulatory announcements and congressional statements concerning the topic. Finally, the topical subscriptions. Visitors can sign up to receive information via email, as it becomes available, on any one or more of the Dodd-Frank topics or even the Dodd-Frank Tracker as a whole. The benefits of this feature are obvious, especially to those whose time must be focused primarily on other things—like running a bank. Subscription links appear throughout the Dodd-Frank Tracker website.

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