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Dodd Frank’s Frightening Progeny

From Kevin LaCroix’s great D&O Diary, here’s some news no one really wants to read:


Although there obviously is no joy in the exercise, the Davis Polk law firm has been diligently tracking the [U.S. federal] agencies’ rulemaking progress. In its May 2012 Dodd-Frank Progress Report (here) the law firm details the current status of the agencies’ rulemaking efforts.

Among other things, the study shows that as of May 1, 2012, a total of 221 Dodd-Frank rulemaking requirement deadlines have passed. Of those 221, 148 (67%) have been missed and 73 (33%) have been met with finalized rules. Regulators have not yet released proposals for 21 of the 148 missed deadlines.

Of the total of 398 rulemakings that Dodd-Frank required, 108 (27.1%) have been met with finalized rules and 146 rules have been proposed that would meet the requirement  (36.7% more). Rules have not been proposed to meet 144 (36.2%) rulemaking requirements.


For those who’ve managed to forget, Congress enacted the 848-page Dodd-Frank financial reform law (here) in early 2010. Among other things (many other things), Dodd Frank created the SEC’s whistleblower reward program for FCPA offenses. 

Kevin LaCroix’s full post is here.

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One of the four versions of Edvard Munch’s The Scream, above, just sold for $119.9 million, making it ‘the most expensive work of art ever to sell at auction,’ according to the New York Times.

We love art. But it’s hard to imagine hanging something on our wall that can also be used to represent the horrors of the federal bureaucracy. That painting is scary.

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