In the eighteen months since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), U.S. financial regulators have engaged in an unprecedented amount of rulemaking activity. The implications of Dodd-Frank, the most comprehensive reform of the U.S. financial regulatory system since the Great Depression, are far-reaching and difficult to follow.

Dodd-Frank contains over 315 rulemaking requirements and 145 study and reporting provisions. Many of the rulemaking and study requirements have ambitious deadlines for finalization. In light of the monumental amount of work and the limited timeframe, regulators have been working at a frenetic pace. However, missed deadlines are becoming a relatively common occurrence, creating significant legal uncertainty. More than 130 deadlines have been missed and approximately 190 rules have yet to be proposed...