Dodd-Frank Act Effective Dates/Rules Promulgation Deadlines
Notes
Title
Sec. 4
FRB/FDIC Joint Final
Rules on Resolution
Plan
FRB Rules on Risk
Committees
The FRB and FDIC are to jointly issue
final rules on the requirements of
resolution plans.
FRB to issue final rules on risk
committee requirements
I
Sec. 165(d)(8)
18 months from
enactment
I
Sec. 165(h)(4)
FRB Title I Final
Rules
FRB is to issue final rules
implementing Title I (other than OFR
issues)
Courts required to establish rules for
expedited liquidation proceedings
I
Sec. 168
1 year after
“transfer date”
(i.e., 1 year after
enactment subject
to extension of up
to 6 months
18 months from
enactment
Court Rules for
Expedited Liquidation
Proceedings
Federal Insurance
Office (FIO)
Federal insurance office to be
established
© 2010 Property Casualty Insurers Association of America
Effective Date
1 day after date
of enactment
(unless otherwise
indicated)
Rule or
Required Action
Provision
General effective date
II
Sec. 202(b)(1)
V
Sec. 4 of bill
Compliance Date
6 months from
enactment
1 day after
enactment
1
Provision
Nonadmitted and
Reinsurance Reform
Act
Source of Strength
Rules
Volcker Rule
(Proprietary Trading)
Notes
Title
V
Sec. 512
Effective Date
12 months after
enactment
If an insured depository institution is
not the subsidiary of a bank holding
company or savings and loan holding
company, the appropriate Federal
banking agency for the insured
depository institution shall require any
company that directly or indirectly
controls the insured depository
institution to serve as a source of
financial strength for such institution.
FSOC to make recommendations on
implementation, including how to
“accommodate business of insurance”
Vi
Sec 616 (d)
Effective on the
transfer date to
the appropriate
federal regulator.
Rule or
Required Action
2 years after
enactment, states
must participate
in uniform
national
insurance
producer
database
The appropriate
federal banking
agencies shall
jointly issue
final rules to
carry out this
section.
Within 6 months
of enactment
VI
Sec. 619
Compliance Date
Not later than 1
year after the
transfer date to the
appropriate federal
regulator
2 years from
promulgation of
final rules (potential
of 3 additional 1year extensions)
Implementation regulations
Earlier of 12
months after regs
promulgated or 2
years after
enactment
© 2010 Property Casualty Insurers Association of America
Within 9 months
of release of
FSOC study
(above)
2
Provision
Regulation of OvertheCounter Swaps
Markets
Notes
CFTC will regulate swaps and related
activities. SEC will regulate security
based swaps and related activities
Title
VII
Bureau of Consumer
Financial Protection
(BCFP)
New consumer financial protection
bureau established to regulate financial
companies for market conduct
(insurers exempt except for FCRA
enforcement)
X
Sec. 1062
Sec. 1100G
Incentive-Based
Compensation
Appropriate Federal Regulators to
prescribe regulations/guidance for
disclosure of incentive-based
compensation arrangements
BCFP to enforce existing and new
consumer mortgage laws and
regulations
Mortgage Reform and
Anti-Predatory
Lending Act
© 2010 Property Casualty Insurers Association of America
Effective Date
On the later of
360 days
after the date of
enactment or, to
the extent
rulemaking is
required, not less
than 60 days after
publication of the
final rule or reg
“Transfer Date”
must be at least
180 days, but not
more than 12
months after
enactment, 12
months
(extensions up to
18 months
possible)
IX
Sec. 956
XIV
Sec. 1400
Rule or
Required Action
Compliance Date
Treasury
Secretary must
set the “Transfer
Date” within 60
days of
enactment
9 months after
enactment
Not later than 12
months after
issuance of final
regs
18 months after
the Transfer Date
in Title X
(BCFP)
3