When fully implemented, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 promises, in President Obama’s words, “clearer accountability in supervision and regulation so that financial firms can operate under a coherent set of rules and expectations,” and “certainty to everybody, from bankers to farmers to business owners to consumers.” In the near term, however, the promise and the reality will be polar opposites. With the enactment of this legislation on July 21, the financial services industry is entering an extended period of regulatory uncertainty unlike any it has ever experienced.