Dodd-Frank Update

• Author: Thomas Velk,Katherine Kalinins
• DOI: 10.1177/0003603X1305800402
• Published date: 01 December 2013
• Date: 01 December 2013
• Subject Matter: Article

THE ANTITRUST BULLETIN: Vol. 58, No. 4/Winter 2013 : 583
Dodd-Frank update
BY KATHERINE KALININS* AND THOMAS VELK**
I.
STATE OF THE LAW
Since completion of the articles in this symposium, the Dodd-Frank Act1
(the Act) has become part of the public law, receiving both praise and
criticism. Since then, “regulators have written 14,000 pages and finalized
155 rules of the . . . Act,” with “243 rules outlined in [the Act]‘s 3,200
pages yet to be written, including some of the cornerstone regulations.”2
As such, the Act has not been ful y implemented and is stil coming into
effect. As of mid-2013, “regulators col aborating to write some 400 new
industry rules”3 are in fact only thirty-nine percent done.4 In response, it
* Third-year law student, McGill University, Montreal, Canada.
** Director, North American Studies, McGill University, Montreal,
Canada.
1
Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010,
Pub. L. No. 111-203, 124 Stat. 1376 (2010).
2
Kayla Tausche & Amara Omeokwe, Dodd-Frank Turns 3, but Slew of
Rules Are Stil Unwritten, CNBC.COM (July 23, 2013), http://www.cnbc.com/id
/100906282.
3
Id.
4
For a full list and timeline of Dodd-Frank implementation, see Securi-
ties & Exchange Comm’n, Implementing Dodd-Frank Wall Street Reform and
Consumer Protection Act—Accomplishments, http://www.sec.gov/spotlight
/dodd-frank/accomplishments.shtml.
© 2013 by Federal Legal Publications, Inc.

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584 : THE ANTITRUST BULLETIN: Vol. 58, No. 4/Winter 2013
is possible to argue that not enough time has passed to recognize and
assess the entirety of the Act’s impact, both legislative and economic.
Nonetheless, progress in implementation has certainly been
made. During the summer of 2013, the U.S. Commodity Futures Trad-
ing Commission (the CFTC) “adopted final guidance regarding the
cross border application of the new derivatives requirements under
the [Act], as well as an interim final exemptive order that phases in
the relevant requirements.”5 Some highlights of the...