2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Dodd-Frank Wall Street Reform and Consumer Protection Act – Regulations and
Studies
(As of November 8, 2010)
Note: All page and section citations refer to the June 29, 2010 House-passed conference report.
Section
Bill Page #
Regulatory
Agencies
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
TITLE I –
FINANCIAL
STABILITY
111(e)(2)
20
Financial Stability
Oversight Council
(FSOC)
Rules for FSOC
organization and
conducting business
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
113
24
FSOC
Rule to give FSOC
authority to require
certain nonbank
financial companies to
be supervised by
Federal Reserve
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
115(c)
30
FSOC
Study of cost, benefit,
feasibility & structure
of contingent capital
requirement for
systemic cos.
2 years after date of
enactment
FLSG, RMC
Spiezio, Leifer, Hughes
123
38
Treasury
Secretary
Study of economic
impact of regulatory
limitations on financial
firms intended to
reduce systemic risk.
180 days after
enactment, and every
5 years thereafter.
FLSG, RMC
Spiezio, Leifer, Hughes
153
41
Office of Financial
Research (OFR)
As necessary to carry
out duties of Office
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
Page 1 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Regarding type and
scope of data to be
collected by OFR
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
Treasury
Secretary
Rules for assessment
base and rates of
financial cos. to fund
OFR
2 years after
enactment
FLSG, RMC
Spiezio, Leifer, Hughes
52
Federal Reserve
Board (FRB)
Rules requiring
systemic cos to
maintain contingent
capital
Subsequent to report
required under sec.
115(c)
FLSG, RMC
Spiezio, Leifer, Hughes
165(e)(1)&(5)
54 and 55
FRB
Rules on concentration
limits, credit exposure
& attribution rule
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
165(f)
55
FRB
Rules on enhanced
public disclosures by
systemic cos.
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
165(g)
55
FRB
Rules governing short
term debt limits for
systemic cos
N/A
FLSG,RMC
Spiezio, Leifer, Hughes
165(h)(2)
56
FRB
Rules requiring and
governing risk
committees in financial
cos.
N/A (but see 165(h)(4) FLSG, RMC
on page 133 re: 15
months from ‘transfer
date’)
Spiezio, Leifer,
Hughes
165(i)(2)(C)
57
Primary federal
financial
regulators in
coordination with
FRB & FIO
Establish rules for
required stress tests
for systemic cos.
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
165(j)(3)
58
FRB
Rules establishing
compliance with
leverage limits
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
Section
Bill Page #
Regulatory
Agencies
154(b)(1)(C)
43
OFR
155(d)
45
165(c)(1)
Page 2 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Rules requiring early
remediation of
financially distressed
systemic co.
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
FRB
Rules establishing
criteria for determining
need to establish
intermediate HC by
systemic cos.
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
61
FRB with FSOC
Rules for exempting
cos. From oversight
under secs. 113 & 115
N/A
FLSG, RMC
Spiezio, Leifer, Hughes
171(b)(7)
65
Federal banking
agencies subject
to FSOC
recommendations
Risk and activity based
capital requirements
for systemic co and
insured depository
institution HCs.
N/A
FLSG, RMC, BTHC
Subgroup
Spiezio, Leifer, Hughes
174
67
Comptroller
General in
consultation with
the FRB, Treasury
& FDIC
Studies on use of
N/A re hybrid capital;
hybrid capital & foreign 18 mos re foreign HCs
bank intermediate HC
capital requirements
FLSG, RMC
Spiezio, Leifer, Hughes
202(d)(5)
75
FDIC
Rules governing
termination of
receivership
N/A
RMC, Solvency Cmte,
FLSG
Spiezio, Leifer,
Mehlman
202(e)
75
Comptroller
General & Admn.
Office of U.S.
Courts
Study of financial co.
liquidation under
Bankruptcy Code
1 year after and
enactment, every year
for the next 3 years,
then once every 5
years
RMC, Solvency Cmte,
FLSG
Spiezio, Leifer,
Mehlman
Regulatory
Agencies
Section
Bill Page #
166(a)
59
FRB with FSOC &
Federal Deposit
Insurance
Corporation
(FDIC)
167(c )
61
170
TITLE II –
ORDERLY
LIQUIDATION
AUTHORITY
Page 3 of 38 pages
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Regulatory
Agencies
Subject
Matter/Summary of
Rule/Study to
develop
Section
Bill Page #
202(f)
76
Comptroller
General
Study of international
coordination of
financial co.
insolvencies
202(g)
76
Comptroller
General
209
86
210(a)(7)(D)
Timing
1 year after enactment
ACLI
Committee/Working
Group/Task Force
ACLI Staff
RMC, International
Cmte, FLSG
Spiezio, Leifer, Smith
Study of banking
1 year after enactment
agency implementation
of prompt corrective
action
RMC, FLSG
Spiezio, Leifer
FDIC in
consultation w/
FSOC
Such rules necessary
to implement T.II
N/A
RMC, FLSG
Spiezio, Leifer
96
FDIC
Rules establishing
interest rate &
payments to claimants
of insolvent covered
financial co.
N/A
RMC, Solvency Cmte,
FLSG
Spiezio, Leifer,
Mehlman
210(c)(8)(H)
117
Primary federal
regulatory
agencies
Rules requiring
financial cos maintain
records re: qualified
financial contracts
2 years after
enactment
RMC, Life Insurance
Investments
Committee (“LIIC”),
FLSG
Spiezio, Leifer,
Wilkerson
210(n)(7)
135
FDIC and
Treasury in
consultation with
FSOC
Rules governing FDIC’s N/A
maximum obligation
limitation
RMC, Solvency Cmte,
FLSG
Spiezio, Leifer,
Mehlman
210(o)(6)
140
FDIC in
consultation w/
Treasury
Rules to carryout
assessment authority
N/A
RMC, Federal Company Spiezio, Leifer, Welsh
Tax Cmte, FLSG
215
146
FSOC
Study on secured
creditor haircuts
1 year after enactment
RMC, LIIC, FLSG
Spiezio, Leifer,
Wilkerson
216
147
FRB in
consultation w/
Office of US
Courts
Study of resolution of
financial cos. Under
chapters 7 & 11 of
Bankruptcy code
1 year after enactment
RMC, FLSG
Spiezio, Leifer
Page 4 of 38 pages
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2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Section
Bill Page #
217
148
Regulatory
Agencies
Subject
Matter/Summary of
Rule/Study to
develop
FRB in
consultation w/
Office of US
Courts
International
coordination of
systemic co.
insolvencies
1 year after enactment
RMC, International
Cmte, FLSG
FRB or OCC
Any regulation
proposed by the OTS
in advance of the
Transfer Date, but
which has not been
published as a final
regulation, shall be
deemed a proposed
regulation of either the
FRB or the OCC, as
appropriate.
1 year after date of
enactment
B/THC Subgroup, RMC, Neill, Spiezio
FLSG
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Spiezio, Leifer, Smith
TITLE III –
TRANSFER OF
POWERS TO THE
COMPTROLLER OF
THE CURRENCY,
FDIC, AND BOARD
OF GOVERNORS
316(d)(1)
Page 5 of 38 pages
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2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
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Regulatory
Agencies
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
316(d)(2)
FRB or OCC
Any interim or final
1 year after date of
OTS regulation that
enactment
has not yet become
effective as of the
Transfer Date, shall
become effective as a
regulation of either the
FRB or the OCC, unless
modified in accordance
with applicable law by
the OCC or FRB, as
appropriate, by any
court or by operation
of law.
B/THC Subgroup, RMC, Neill, Spiezio
FLSG
331(b)(2)
FDIC
FDIC must amend
1 year after date of
regulations under the
enactment
FDIA to define the
term “assessment
base”, an amount that
the FDIC determines is
necessary to establish
assessments
consistent with the
definition of a custodial
bank or a banker’s
bank as those terms
are defined under
FDIA.
B/THC Subgroup, RMC, Neill, Spiezio
FLSG
Page 6 of 38 pages
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Section
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Bill Page #
Regulatory
Agencies
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
TITLE IV –
REGULATION OF
ADVISORS TO
HEDGE FUNDS &
OTHERS
404
200-203
406
203
412
206
SEC
The SEC shall issue
rules requiring each
investment advisor to
a private fund to file
reports containing
such information as
the SEC deems
necessary for the
protection of investors
or the assessment of
systemic risk.
N/A
Life Insurance
Investments
Committee (“LIIC”)
Wilkerson, Melnyk
SEC, CFTC, FSOC
Disclosure Rules on
Private Funds – will
jointly promulgate
rules to establish the
form of the reports
required to be filed
with the SEC under
subsection 204(b) by
investment advisers
that are registered
both under this title
and the Commodity
Exchange Act.
Not later than 12
months after
enactment
LIIC
Wilkerson, Melnyk
Comptroller
General of the US
(GAO)
Custody rule costs –
compliance costs
associated with
Exchange Commission
rules 204-2 and rule
206(4)-2
3 years
LIIC
Wilkerson, Melnyk
Page 7 of 38 pages
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2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Section
Bill Page #
415
207
Regulatory
Agencies
Subject
Matter/Summary of
Rule/Study to
develop
Comptroller
General of the US
(GAO)
Appropriate criteria for
determining financial
thresholds to qualify
for accredited investor
status
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
3 years
LIIC
Wilkerson, Melnyk
416
208
Comptroller
General of the US
(GAO)
Feasibility of self1 year
regulatory organization
for private funds
LIIC
Wilkerson, Melnyk
417(a)(1)
208
SEC
Current scholarship on, 2 years
and state of, short
selling
LIIC
Wilkerson, Melnyk
417(a)(2)
208
SEC
Feasibility of public
reporting of short
selling
1 year
LIIC
Wilkerson, Melnyk
TITLE V INSURANCE
313(f)(2)
212
Federal Insurance
Office (FIO)
Publish notice in
Federal Register of
potential pre-emption
of state law
Prior to pre-emption
determination
RMC, International
Cmte, FLSG,SLSG
Spiezio, Hughes, Cobb,
Smith
313(h)
213
Treasury
Rules, orders and
policies to implement
sec. 313 (T.V, subt. A)
N/A
RMC, FLSG
Spiezio, Hughes
313(n)(1)
214
FIO
Report to Congress on
FIO pre-emptions
Every year on 9/30
starting on 9/30/11
RMC, International
Cmtte, FLSG, SLSG
Spiezio, Hughes, Cobb,
Smith
313(n)(2)
214
FIO
Report to Congress on
insurance industry
Every year on 9/30
starting on 9/30/11
RMC, FLSG
Spiezio, Hughes
Page 8 of 38 pages
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2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
Section
Bill Page #
Regulatory
Agencies
313(o)
214
FIO
Report to Congress on
global reinsurance
market & effect of
Nonadmitted and
Reinsurance Act of
2010
Re: global reinsurance
market by 9/30/12; re
effect of Act by 1/1/13
and again on 1/1/15
Reinsurance Cmte,
International Cmte
Cobb, Smith
313(p)
215
FIO
Study & report on
insurance regulation
modernization
18 months after
enactment
RMC, FLSG
Spiezio, Hughes
603(b)(1)-(3)
GAO (Controller
General)
Study on whether it is
18 mos. after date of
necessary to eliminate enactment
BHCA exemptions for
holding companies of
credit card banks,
industrial banks, trust
companies and savings
associations.
Bank/Thrift Holding
Company Subgroup
(B/THC Subgroup),
RMC, FLSG
Spiezio, Neill
616(a)
FRB
Regulations to make
capital requirements
for BHCs
countercyclical.
Bank/Thrift Holding
Company Subgroup
(B/THC Subgroup),
RMC, FLSG
Spiezio, Neill
Timing
ACLI Staff
TITLE VI –
IMPROVEMENTS
TO REGULATION
OF BANK AND
SAVINGS
ASSOCIATION
HOLDING
COMPANIES AND
DEPOSITORY
INSTITUTIONS
1 year after date of
enactment
Page 9 of 38 pages
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Bill Page #
Regulatory
Agencies
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
616(b)
Federal banking
agencies
Regulations to make
capital requirements
for savings and loan
holding companies
countercyclical
1 year after date of
enactment
Bank/Thrift Holding
Company Subgroup
(B/THC Subgroup),
RMC, FLSG
Neill, Spiezio
616(c)
Federal banking
agencies
Regulations to require
1 year after date of
bank holding
enactment
companies and savings
and loan holding
companies to serve as
a source of strength
for depository
institution subsidiaries
Bank/Thrift Holding
Company Subgroup
(B/THC Subgroup),
RMC, FLSG
Neill, Spiezio
250
FSOC
study on
implementation of
Volcker Rule
6 mos. After date of
enactment
Bank/Thrift Holding
Company Subgroup
(B/THC Subgroup),
RMC, FLSG
Spiezio, Neill
13(b)(2)
251
Bank/Thrift Holding
Company Subgroup
(B/THC Subgroup),
RMC, FLSG
Spiezio, Neill
256
Rules to carryout
Volcker Rule
provisions, w/
consideration of
findings of FSOC
9 mos. After
completion of FSOC
study (above)
13(d)(2)(B)
13(e)
257
FRB for B/THCs;
federal banking
agencies(jointly)
for insured
depository
institutions; CFTC
& SEC for
institutions they
respectively
regulate; to be
coordinated by
the FSOC
13(c)(6)
253
FRB
Rules to implement
divestiture
requirements and
extended transition for
illiquid funds
6 mos after date of
enactment
Bank/Thrift Holding
Company Subgroup
(B/THC Subgroup),
RMC, FLSG
Spiezio, Neill
(T. VI, Sec. 619)
13(b)(1)
Page 10 of 38 pages
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Subject
Matter/Summary of
Rule/Study to
develop
Bill Page #
Regulatory
Agencies
719
285
CFTC
Study of the effects (if
any) of the position
limits imposed
pursuant to the other
provisions of this title
on excessive
speculation and on the
movement of
transactions from
exchanges in the
United States to
trading venues outside
the United States.
719
286
CFTC & SEC
Study of the feasibility Within 8 months after
of requiring the
the date of the
derivatives industry to enactment
adopt standardized
computer-readable
algorithmic
descriptions which may
be used to describe
complex and
standardized financial
derivatives
Section
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
TITLE VII – WALL
STREET
TRANSPARENCY &
ACCOUNTABILITY
Within 12 months after ACLI Life Insurance
the imposition of
Investments
position limits
Committee (“LIIC”)
pursuant to the other
provisions of Title VII
LIIC

Wilkerson, Melnyk
Wilkerson, Melnyk
Rules related to ACLI’s legislative priorities in the derivatives title that have a direct impact on life insurers are denoted with an “*”; other rules primarily
impact participants other than life insurers but present secondary priorities for life insurers because they may increase the costs of doing business with
derivatives counterparties.
Page 11 of 38 pages
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Bill Page #
Regulatory
Agencies
719
286
CFTC & SEC
719
287*
CFTC & SEC
Subject
Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Study relating to (i)
Not later than 18
swap regulation in the months after the date
United States, Asia,
of enactment
and clearing house and
clearing agency
regulation in the
United States, Asia,
and Europe and that
identifies areas of
regulation that are
similar in the United
States, Asia and
Europe and other
areas of regulation
that could be
harmonized
LIIC
Wilkerson, Melnyk
Study to determine
whether stable value
contracts fall within
the definition of a
swap. If CFTC & the
SEC determine that
stable value contracts
fall within the
definition of a swap,
they jointly shall
determine if an
exemption for stable
value contracts from
the definition of swap
is appropriate and in
the public interest
LIIC
Wilkerson, Melnyk
Timing
Not later than 15
months after the date
of the enactment
Page 12 of 38 pages
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2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
No time limit.
LIIC
Wilkerson, Melnyk
CFTC
May include within, or
No time limit.
exclude from, the term
'floor broker' any
person in or
surrounding any pit,
ring, post, or other
place provided by a
contract market for the
meeting of persons
similarly engaged who
trades for any other
person
LIIC
Wilkerson, Melnyk
CFTC
May include within, or
No time limit.
exclude from, the term
'floor trader' any
person in or
surrounding any pit,
ring, post, or other
place provided by a
contract market for the
meeting of persons
similarly engaged who
trades solely for such
person's own account
LIIC
Wilkerson, Melnyk
Section
Bill Page #
Regulatory
Agencies
721(a)(6)
290
CFTC
May include within, or
exclude from, the term
'commodity pool
operator' any person
engaged in a business
that is of the nature of
a commodity pool,
investment trust,
syndicate, or similar
form of enterprise
721(a)(10)
291
721(a)(11)
291
Page 13 of 38 pages
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Agencies
721(a)(13)
291
CFTC
721(a)(15)
293
CFTC
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
May include within, or
exclude from, the term
'futures commission
merchant' any person
who engages in
soliciting or accepting
orders for, or acting as
a counterparty in, any
agreement, contract,
or transaction subject
to this Act, and who
accepts any money,
securities, or property
(or extends credit in
lieu thereof) to
margin, guarantee, or
secure any trades or
contracts that result or
may result therefrom
No time limit.
LIIC
Wilkerson, Melnyk
May include within, or
exclude from, the term
'introducing broker'
any person who
engages in soliciting or
accepting orders for
any agreement,
contract, or
transaction subject to
this Act, and who does
not accept any money,
securities, or property
( or extend credit in
lieu thereof) to
margin, guarantee, or
secure any trades or
contracts that result or
may result therefrom
No time limit.
LIIC
Wilkerson, Melnyk
Page 14 of 38 pages
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Regulatory
Agencies
721(a)(16)
294 *
CFTC
721(b)
301 *
CFTC
Subject
Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Define by rule or
Within one year after
regulation the term
enactment.
'substantial position' at
the threshold that the
CFTC determines to be
prudent for the
effective monitoring,
management, and
oversight of entities
that are systemically
important or can
significantly impact the
financial system of the
United States
LIIC
Wilkerson, Melnyk
May adopt a rule to
define (1) the term
"commercial risk"; and
(2) any other term
included in an
amendment to the
Commodity Exchange
Act (7 U.S.C. 1 et
seq.) made by this
subtitle.
LIIC
Wilkerson, Melnyk
Timing
Within one year after
enactment.
Page 15 of 38 pages
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Agencies
721(c)
301 *
CFTC
To include transactions
and entities that have
been structured to
evade this subtitle (or
an amendment made
by this subtitle), the
Commodity Futures
Trading Commission
shall adopt a rule to
further define the
terms "swap", "swap
dealer", "major swap
participant", and
"eligible contract
participant"
723(a)(3)
308
CFTC
Shall adopt rules for a
derivatives clearing
organization's
submission for review,
pursuant to this
paragraph, of a swap,
or a group, category,
type, or class of
swaps, that it seeks to
accept for clearing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Within one year after
enactment.
LIIC
Wilkerson, Melnyk
Within one year after
enactment.
LIIC
Wilkerson, Melnyk
Timing
Page 16 of 38 pages
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ACLI Issue Status Chart
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Section
Bill Page #
Regulatory
Agencies
723(a)
309
CFTC
725(c)
323
Derivatives
Clearing
Organizations
Subject
Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Shall prescribe rules
Within one year after
under this subsection
enactment.
(and issue
interpretations of rules
prescribed under this
subsection) as
determined by the
CFTC to be necessary
to prevent evasions of
the mandatory clearing
requirements under
Act
LIIC
Wilkerson, Melnyk
Each derivatives
clearing organization
shall"(i) establish and
enforce rules to
minimize conflicts of
interest in the decision
-making process of the
derivatives clearing
organization; and "(ii)
establish a process for
resolving conflicts of
interest
LIIC
Wilkerson, Melnyk
Timing
No time limit.
Page 17 of 38 pages
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ACLI Issue Status Chart
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Section
Bill Page #
Regulatory
Agencies
725(d)
323
CFTC
Subject
Matter/Summary of
Rule/Study to
develop
Timing
Shall adopt rules
No time limit.
mitigating conflicts of
interest in connection
with the conduct of
business by a swap
dealer or a major swap
participant with a
derivatives clearing
organization, board of
trade, or a swap
execution facility that
clears or trades swaps
in which the swap
dealer or major swap
participant has a
material debt or
material equity
investment
ACLI
Committee/Working
Group/Task Force
ACLI Staff
LIIC
Wilkerson, Melnyk
Page 18 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Section
Bill Page #
Regulatory
Agencies
726(a)
326
CFTC
Subject
Matter/Summary of
Rule/Study to
develop
To mitigate conflicts of
interest, the CFTC
shall adopt rules which
may include numerical
limits on the control
of, or the voting rights
with respect to, any
derivatives clearing
organization that
clears swaps, or swap
execution facility or
board of trade
designated as a
contract market that
posts swaps or makes
swaps available for
trading, by a bank
holding company (as
defined in section 2 of
the Bank Holding
Company Act of 1956
with total consolidated
assets of
$50,000,000,000 or
more, a nonbank
financial company (as
defined in section 102)
supervised by the
Board, an affiliate of
such a bank holding
company or nonbank
financial company, a
swap dealer, major
swap participant, or
associated person of a
swap dealer or major
swap participant
Timing
Within 180 days after
enactment
ACLI
Committee/Working
Group/Task Force
ACLI Staff
LIIC
Wilkerson, Melnyk
Page 19 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Authorized and
required to provide by
rule for the public
availability of swap
transaction and pricing
data
No time limit.
LIIC
Wilkerson, Melnyk
CFTC
Establish and enforce
rules to minimize
conflicts of interest in
the decision-making
process of the swap
data repository, and
establish a process for
resolving conflicts of
interest
No time limit.
LIIC
Wilkerson, Melnyk
CFTC
Interim final rule
providing for the
reporting of each swap
entered into before the
date of enactment
within 90 days of the
date of enactment
LIIC
Wilkerson, Melnyk
Section
Bill Page #
Regulatory
Agencies
727
327 *
CFTC
728
332
729
332 *
Page 20 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
In consultation with
the CFTC and the SEC,
shall jointly adopt
rules for swap dealers
and major swap
participants, with
respect to their
activities as a swap
dealer or major swap
participant, for which
there is a prudential
regulator imposing:
capital requirements;
and both initial and
variation margin
requirements on all
swaps that are not
cleared by a registered
derivatives clearing
organization.
No time limit.
LIIC
Wilkerson, Melnyk
CFTC
Shall adopt rules
governing reporting
and recordkeeping for
swap dealers and
major swap
participants
No time limit.
LIIC
Wilkerson, Melnyk
CFTC
Shall prescribe rules
governing business
conduct standards for
swap dealers and
major swap
participants
No time limit.
LIIC
Wilkerson, Melnyk
Regulatory
Agencies
Section
Bill Page #
731
336*
Prudential
Regulators in
Consultation with
the SEC
731
338 *
731
341*
Page 21 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Shall adopt rules
governing
documentation
standards for swap
dealers and major
swap participants
No time limit.
LIIC
Wilkerson, Melnyk
CFTC & SEC
May promulgate rules
defining the universe
of swaps that can be
executed on a swap
execution facility
No time limit.
LIIC
Wilkerson, Melnyk
349
CFTC
Shall prescribe rules
governing the
regulation of
alternative swap
execution facilities
No time limit.
LIIC
Wilkerson, Melnyk
356
CFTC
By rule, regulation, or
order, may exempt,
conditionally or
unconditionally, any
person or class of
persons, any swap or
class of swaps, any
contract of sale of a
commodity for future
delivery or class of
such contracts, any
option or class of
options, or any
transaction or class of
transactions from any
requirement it may
establish with respect
to position limits
No time limit.
LIIC
Wilkerson, Melnyk
Section
Bill Page #
Regulatory
Agencies
731
341 *
CFTC
733
344 *
733
737
Page 22 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Rules to implement
new statutory
framework for
certification and
approval of new
products – applicable
to designated contract
markets (DCM)
derivatives clearing
organizations (DCO),
swap execution
facilities (SEF), and
swap data repositories
(SDR).
No time limit.
LIIC
Wilkerson, Melnyk
CFTC
Grants CFTC authority
to amend the
Commodity Exchange
Act (CEA) to prohibit
certain trading
practices deemed
disruptive of fair and
equitable trading
No time limit.
LIIC
Wilkerson, Melnyk
SEC
Regarding the term
No time limit.
“security-based swap”
define, by rule or
regulation, the term
'substantial position' at
the threshold that the
CFTC determines to be
prudent for the
effective monitoring,
management, and
oversight of entities
that are systemically
important or can
significantly impact the
financial system of the
United States
LIIC
Wilkerson, Melnyk
Section
Bill Page #
Regulatory
Agencies
745
367
CFTC
747
371
761(a)
388 *
Page 23 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Not later than 1 year
after the date of the
enactment
LIIC
Wilkerson, Melnyk
No time limit.
LIIC
Wilkerson, Melnyk
SEC
Shall adopt rules
No time limit.
governing persons that
are registered as
clearing agencies for
security-based swaps
LIIC
Wilkerson, Melnyk
SEC
Shall prescribe rules
governing the
regulation of securitybased swap execution
facilities under this
section
LIIC
Wilkerson, Melnyk
Section
Bill Page #
Regulatory
Agencies
763
396 *
SEC
Shall adopt rules for a
clearing agency's
submission for review,
pursuant to this
subsection, of a
security-based swap,
or a group, category,
type, or class of
security-based swaps,
that it seeks to accept
for clearing
763
401
SEC
To be registered and
to maintain
registration as a
clearing agency that
clears security-based
swap transactions, a
clearing agency shall
comply with such
standards as the CFTC
may establish by rule
763
401
763
407
Timing
No time limit.
Page 24 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Shall, by rules and
No time limit.
regulations, define and
prescribe means
reasonably designed to
prevent, such
transactions, acts,
practices, and courses
of business as are
fraudulent, deceptive,
or manipulative, and
such quotations as are
fictitious concerning
security-based swaps
LIIC
Wilkerson, Melnyk
CFTC
By rule or regulation,
as necessary or
appropriate in the
public interest or for
the protection of
investors, establish
limits (including
related hedge
exemption provisions)
on the size of positions
in any security-based
swap, including
aggregate positions
No time limit.
LIIC
Wilkerson, Melnyk
CFTC
Authorized to provide
by rule for the public
availability of securitybased swap
transaction, volume,
and pricing data
No time limit.
LIIC
Wilkerson, Melnyk
Section
Bill Page #
Regulatory
Agencies
763
410
SEC
763
410
763
412
Timing
Page 25 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Establish and enforce
rules to minimize
conflicts of interest in
the decision-making
process of the
security-based swap
data repository
No time limit.
LIIC
Wilkerson, Melnyk
SEC
May prescribe rules
applicable to securitybased swap dealers
and major securitybased swap
participants, including
rules that limit the
activities of non-bank
security-based swap
dealers and major
security-based swap
participants
No time limit.
LIIC
Wilkerson, Melnyk
SEC
Shall issue rules under
this section to provide
for the registration of
security-based swap
dealers and major
security-based swap
participants
Within one year after
enactment
LIIC
Wilkerson, Melnyk
Regulatory
Agencies
Section
Bill Page #
763
417
Security-based
swap repository
764
418
764
418
Page 26 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
No time limit.
LIIC
Wilkerson, Melnyk
Shall adopt rules which Within 180 days of
may include numerical enactment
limits on the control
of, or the voting rights
with respect to, any
clearing agency that
clears security-based
swaps, or on the
control of any securitybased swap execution
facility or national
securities exchange
that posts or makes
available for trading
security-based swaps,
by a bank holding
company
LIIC
Wilkerson, Melnyk
Shall promulgate an
interim final rule
providing for the
reporting of each
security-based swap
entered into before the
date of enactment
LIIC
Wilkerson, Melnyk
Section
Bill Page #
Regulatory
Agencies
764
425
SEC
Shall adopt rules
governing
documentation
standards for securitybased swap dealers
and major securitybased swap
participants
765
429
SEC
766
431
SEC
Within 90 days of the
date of enactment
Page 27 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Regulatory
Agencies
Subject
Matter/Summary of
Rule/Study to
develop
454
Board of
Governors
(Federal
Reserve),
Supervisory
Agencies
Authorized to prescribe NA
rules and issue orders
as may be necessary
to administer and
carry out their
respective authorities
Life Insurance
Investments
Committee (“LIIC”)
Wilkerson, Melnyk
913
458
SEC
Study and rulemaking
regarding obligation of
brokers, dealers and
investment advisers
6 months/Date of
Enactment
Standard of Care
Working Group
Leifer
914
464
SEC
Study on enhancing
investment advisers
examinations
180 days/ Date of
Enactment
Standard of Care
Working Group
Leifer
917
470
SEC
Study regarding
financial literacy
among investors
2 years/ Date of
Enactment
Standard of Care
Working Group
Leifer
918
470
Comptroller
General of the
U.S.
Study regarding
mutual fund
advertising
18 months/Date of
Enactment
Standard of Care
Working Group
Leifer
Section
Bill Page #
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
TITLE VIII –
PAYMENT,
CLEARING, &
SETTLEMENT
SUPERVISION
810
TITLE IX –
INVESTOR
PROTECTIONS &
IMPROVEMENTS
TO THE
REGULATON OF
SECURITIES
Page 28 of 38 pages
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ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
Section
Bill Page #
Regulatory
Agencies
919
471
SEC
Clarification of
authority to require
investor disclosure
prior to purchase of
investment products
No deadline
Standard of Care
Working Group
Leifer
919B
472
SEC
Study on improved
access to information
on broker-deals &
investment advisers
6 months/Date of
Enactment
Standard of Care
Working Group
Leifer
919C
472
Comptroller
General of the
U.S.
Study on financial
planners and the use
of financial
designations
180 days/ Date of
Enactment
Standard of Care
Working Group
Leifer
921
474
SEC
Authority to restrict
mandatory pre-dispute
arbitration
No deadline
Standard of Care
Working Group
Leifer
939A
521
Each Federal
Agency with
regulations
requiring review
of
creditworthiness
of a security or
money market
instrument, or
referencing credit
rating agencies
Replace all regulatory
references to credit
rating agencies with
standards of credit
worthiness that each
respective agency
determines are
appropriate.
Within one year after
enactment
LIIC
Wilkerson, Melnyk
939B
522
SEC
Requires SEC to
amend Reg FD to
remove disclosure
exemption for NRSRO
for purpose of
determining credit
ratings.
No deadline
Securities and
Regulation
Committee/LIIC
Wilkerson, Melnyk
Timing
Page 29 of 38 pages
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ACLI Staff
ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
Section
Bill Page #
Regulatory
Agencies
975(a)
550
SEC
Develop process for
registration of
municipal securities
advisors
Effective 10/1/10 to
12/31/10
Distribution
Committee, Securities
and Regulation
Committee
989A
576
Office of Financial
Literacy (Bureau
of Consumer
Financial
Protection)
Grants to states
relating to senior
designations &
suitability
No deadline
Distribution Committee Leifer, Ireland
584
SEC
Further promoting the
adoption of NAIC
Model Regulations that
enhance protection of
seniors & other
consumers
Benefits commence
June 16, 2013
Distribution Committee Leifer, Ireland
1013(b)(3)(C)
604
Bureau
Complaints regarding
consumer financial
products
Annual Report not
later than 3/31
Distribution Committee Leifer
1013(d)(4)
606
Bureau
Report on financial
literacy activities
24 months/Date of
Enactment; then
annually
Distribution Committee Leifer
989(J)
Timing
ACLI Staff
Liefer, Wilkerson
$8,000,000 authorized
2011-2015
TITLE X – BUREAU
OF CONSUMER
FINANCIAL
PROTECTION
While there is not a statutory mandate in the Dodd-Frank law to create such a rule, the SEC currently does not have a process
to register municipal investment advisors and needs to create a rule to comply with Section 975.

Page 30 of 38 pages
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ACLI Issue Status Chart
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Regulatory
Agencies
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
Section
Bill Page #
1013(d)(7)(A)
606
Comptroller
General of the
U.S.
Feasibility of
certification
program/financial
literacy
1 year/Date of
Enactment
Distribution Committee Leifer
1013(g)
608
Bureau (Office of
Financial
Protection of
Older Americans)
Best practices for
seniors, certifications
for advisors, LTC &
other services
18
months/Establishment
of Office
Distribution Committee Leifer
1016(b)
609
Bureau
Report on consumer
problems obtaining
financial products,
analysis of consumer
complaints, significant
Bureau rules and
orders, among number
of other things
Semi- annual reports
Distribution Committee Leifer
1022(b)
616
Bureau
General rulemaking
authority to implement
Federal consumer
financial laws,
including FCRA
No deadline
Distribution
Committee/Privacy
Committee
1022(c)(1)-(4)
617
Bureau
Monitoring for risks to
consumers in offering
or provision of
consumer financial
products or services
Not fewer than 1
report of significant
findings each calendar
year
Distribution Committee Leifer
1022(c)(6)
618
Bureau
Rulemaking regarding
confidential treatment
of information
obtained implementing
Federal consumer
financial law
No deadline
Privacy Committee
Page 31 of 38 pages
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ACLI Staff
Leifer/Meyer
Meyer
ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
Rulemaking authority
regarding registration
requirements
applicable to covered
person, other than
insured depository
institution or insured
credit union
No deadline
Distribution Committee Leifer
Bureau & FTC
Definition of “covered
person” as nondepository entity
offering loan
origination & other
services
1 year after transfer
date
Reverse Mortgage
Working Group
639
Bureau
Study of arbitration
agreements used by
covered persons;
rulemaking
No deadline
Distribution Committee Leifer
1031(b)
641
Bureau
General rulemaking
regarding disclosure,
unfair, deceptive
practices & other
subjects (covered
persons)
No deadline
Reverse Mortgage
Working Group
Leifer
1032(f)
643
Bureau
Rulemaking -integrated disclosure
for mortgage loans
1 year of transfer date
Reverse Mortgage
Working Group
Leifer
1074(a)
703
Treasury
Future of
Fannie/Freddie &
reform of housing
finance
January 31, 2011
Reverse Mortgage
Working Group
Leifer
1076
711
Bureau
Study & regulation of
reverse mortgages
1 year from transfer
date
Reverse Mortgage
Working Group
Leifer
Section
Bill Page #
Regulatory
Agencies
1022(c)(7)
619
Bureau
1024(a)(2)
622
1028(a)
Page 32 of 38 pages
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ACLI Staff
Leifer
ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Study on differences
1 year/Date of
between consumer and Enactment
credit scores
Privacy Committee
Meyer
Bureau
Rulemaking authority
to implement number
of specific FCRA and
FACT Act provisions,
including section
relating to affiliate
sharing
No deadline
Privacy Committee
Meyer
727
Bureau
General rulemaking
authority to implement
FCRA (other than
sections relating to
Red Flags Guidelines
and disposal of
records)
No deadline
Privacy Committee
Meyer
732
CFTC
To amend the CFTC’s
GLBA privacy of
consumer financial
information rules to
broaden their scope to
apply to “swap
dealers” and “major
swap participants” and
to make other
conforming
amendments to the
rules required under
Titles VII and X.
No time limit
Privacy Committee,
LIIC
Meyer
Section
Bill Page #
Regulatory
Agencies
1078
713
Bureau
1088
724
1088(e)
1093
Timing
Page 33 of 38 pages
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Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
ACLI Staff
“…as soon as
practicable after date
of enactment.”
FLSG, RMC
Spiezio, Kline
Not later than 30
months after
enactment.
FLSG
Spiezio, Kline
FLSG, Insurance
Holding Company
Supervision WG
Spiezio, Kline, Neill
Bill Page #
Regulatory
Agencies
1101(a)(6)(B)(1)
2011
Federal Reserve
Develop rules to
ensure emergency
lending programs
provide market
liquidity and not aid a
failing institution.
1103(b)(8)
2027
Federal Reserve
(Inspector
General)
Study on impact of
Fed’s FOIA exemption
and the ability of the
public to access
information on Fed’s
economic emergency
programs.
1105(a)
2031
Federal Reserve
in coordination
with FDIC
Develop rules to create N/A
a program to
guarantee obligations
of solvent insured
depository institutions
and holding companies
during times of stress.
Section
Timing
TITLE XI –
FEDERAL
RESERVE SYSTEM
PROVISIONS
Page 34 of 38 pages
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2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Bill Page #
Regulatory
Agencies
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
N/A
FLSG
Kline, Lovendusky
TITLE XII –
IMPROVING
ACCESS TO
MAINSTREAM
FINANCIAL
INSTITUTIONS
1209(a)
2056
Treasury
Department
Develop rules to
establish grant
programs to enable
low and moderate
income individuals to
establish one or more
accounts in a federally
insured depository
institution.
TITLE XIII – PAY
IT BACK ACT
No rulemaking
provisions in this Title.
Kline, Neill
TITLE XIV –
MORTGAGE
REFORM & ANTIPREDATORY
LENDING ACT
1403
2082
Federal Reserve
(Board of
Governors)
Prescribe rules to
prohibit mortgage
originators from
steering consumers to
unsuitable loans.
Must be in final form
FLSG
18 months after
designated transfer
date. Rules take effect
12 months after
issuance
Page 35 of 38 pages
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Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
Develop rules to
prohibit or condition
terms or practices in
residential mortgage
loans that the Board
deems predatory or
unfair.
“”
FLSG
Kline, Leifer
Federal Reserve
(Board of
Governors)
Prescribe regulations
that revise, add to, or
subtract from criteria
that define “qualified
mortgage.”
“”
FLSG
Kline, Leifer
2125
GAO
Study to determine
effects of this Title on
availability and
affordability of credit.
1 year after enactment
FLSG
Kline, Leifer
1446
2169
HUD Secretary
Study on root causes
of foreclosure.
1 year after enactment
FLSG
Kline, Leifer
1471
2205
Fed Board, with
OCC, FDIC,
NCUA, FHFA, and
BCFP
Develop rules to
establish property
appraisal requirements
90 days after
enactment.
FLSG
Kline, Leifer
1124
2223
Fed Board, with
OCC, FDIC,
NCUA, FHFA, and
BCFP
Develop rules to
establish minimum
requirements States
will use when
registering appraisal
management
companies.
N/A
FLSG
Kline, Leifer
1125(b)
2239
Fed Board, with
OCC, FDIC,
NCUA, FHFA, and
BCFP
Promulgate rules to
create quality control
standards for use of
automated valuation
models for mortgage
lending purposes.
N/A
FLSG
Kline, Leifer
Regulatory
Agencies
Section
Bill Page #
1405(a)
2086
Federal Reserve
(Board of
Governors)
1412
2104
1421(a)
Page 36 of 38 pages
© American Council of Life Insurers, 101 Constitution Avenue, NW, Washington, D.C. 20001-2133. All rights reserved.
ACLI Issue Status Chart
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Subject
Matter/Summary of
Rule/Study to
develop
ACLI
Committee/Working
Group/Task Force
ACLI Staff
12 months after
enactment
FLSG
Kline, Leifer
N/A
FLSG
Kline , Leifer
SEC
Promulgate rules that
N/A
require all persons that
file reports with the
SEC to disclosure
annually if conflict
minerals are necessary
for products produced
by such persons.
FLSG
Kline, Lovendusky
FDIC
Study to evaluate the
definition of “core
deposits” and effects
on calculating
insurance premiums
payable to the DIF.
FLSG
Kline, Lovendusky
Section
Bill Page #
Regulatory
Agencies
1476
2246
GAO
Study on the
effectiveness of
various appraisal
methods and valuation
models.
1492(a)
2261
GAO
Study on effectiveness
of government efforts
to combat mortgage
foreclosure rescue
scams and loan fraud
1502(b)(1)(A)
2280
1506(a)
2305
Timing
TITLE XV –
MISCELLANEOUS
PROVISIONS
1 year after enactment
Page 37 of 38 pages
© American Council of Life Insurers, 101 Constitution Avenue, NW, Washington, D.C. 20001-2133. All rights reserved.
ACLI Issue Status Chart
Section
2010 Dodd-Frank Wall Street Reform Regulation and Study Tracking Chart
Bill Page #
Regulatory
Agencies
861
IRS
Subject
Matter/Summary of
Rule/Study to
develop
Timing
ACLI
Committee/Working
Group/Task Force
ACLI Staff
TITLE XVI –
SECTION 1256
CONTRACTS
1601
Treasury
The term “Section
1256 Contract” does
not include interest
rate swaps or similar
agreements
Taxable years
beginning after date of
enactment
Company Taxation –
Federal Committee
Page 38 of 38 pages
© American Council of Life Insurers, 101 Constitution Avenue, NW, Washington, D.C. 20001-2133. All rights reserved.
Welsh