By J. Preston Carter, J.D., LL.M., Editor, Financial Privacy Law Guide, CCH Federal Banking Law Reporter, State Banking Law Reporter and Bank Digest; co-author, Dodd-Frank Wall Street Reform and Consumer Protection Act—Law, Explanation and Analysis.
An annual Government Accountability Office study of financial services regulations, mandated by the Dodd-Frank Act, has resulted in no recommendations, but reiterates the GAO's 2011 recommendations that the federal financial regulators more fully incorporate the Office of Management and Budget's guidance into their rulemaking policies and that the Financial Stability Oversight Council work with federal financial regulators to establish formal interagency coordination policies for rulemaking.
- the regulatory analyses federal agencies performed for rules issued pursuant to the Dodd-Frank Act;
- how the agencies consulted with each other in implementing the final rules to avoid duplication or conflicts; and
- what is known about the impact of the Dodd-Frank Act rules.
The GAO identified 66 final Dodd-Frank Act rules in effect between July 21, 2011, and July 23, 2012. The agency examined the regulatory analyses for the 54 regulations that were substantive; conducted case studies on the regulatory analyses for four of the 19 major rules; conducted case studies on interagency coordination for three other rules; and developed indicators to assess the impact of the act's systemic risk provisions and regulations.