Financial Services Regulatory Reform Update - March 11, 2011


The growing chorus of those voicing concerns about the short deadlines and voluminous amounts of rulemakings necessary to implement the law appear to only be growing louder and stronger as the one-year anniversary approaches. Acting somewhat as a counterweight to those critics are those within both the Administration and Congress who have spoken about the potential consequences that could result from a hasty rulemaking process. However, this week saw a dramatic increase in the public statements from elected officials urging regulators to slow down and assess the impact on the financial industry before plowing forward. Despite the rise of this chorus, there have been no steps actively taken toward legislatively altering the Dodd-Frank mandated deadlines, leading some to conclude that certain Dodd- Frank deadlines may come and go without either final regulatory action or legislative relief.

Congress’s attention continues to be focused on the economy and jobs, and House Republicans unveiled another continuing resolution (CR) proposal (a “stopgap funding” bill to keep the government running, until Congress can agree on an actual budget plan) earlier this afternoon. The current CR will fund the government through March 18th, at which point if Congress is unable to pass another CR or a full year funding bill it will shut down. Although the White House and Congress continue to negotiate a bill to keep the government operating for the rest of the year, it is likely that another short-term funding extension will be required to allow legislators and the Obama administration more time to negotiate a final agreement for the rest of FY2011 (which is nearly half over). We believe that both sides are using the need to clear a “debt ceiling” measure in mid-April to early May as the wall necessary to push for final passage of a year long budget measure.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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